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Royalty agreement renewed is in substance a new agreement & therefore entitled to lower rate of withholding tax
Case Law Details
- Case Name
- Income Tax Officer (International Taxation) Vs. M/s. National Engineering Industries Ltd. (ITAT Kolkata)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2009- 10
- Courts
- ITAT Kolkata
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Income Tax Officer (International Taxation) Vs. M/s. National Engineering Industries Ltd., (ITAT Kolkata), ITA No. 1270 and 1271/Kol/2010 dated 28th January, 2011
Facts
• National Engineering Industries Ltd. (the taxpayer) had entered into a License & Technical Assistance agreement with Brenco Inc., USA on 19th August, 2002 which expired on 25th June, 2007. Under the agreement the taxpayer was required to pay a certain amount as royalty to Brenco Inc.
• The taxpayer entered into a new agreement with Brenco Inc., USA on 17th August, 2007 wherein at clause (e) it was sta...
Can anyone tell me where the above case of Income Tax Officer (International Taxation) Vs. M/s. National Engineering Industries Ltd., Kolkata – ITA No. 1270 and 1271/Kol/2010 dated 28th January, 2011
could be downloaded from? Its urgent.