Royalty received in pursuance to agreement entered into before 1976 is not covered u/s. 115A of the Income Tax Act

Mumbai bench of the Income-tax Appellate Tribunal (the Tribunal) in the case of Siemens Aktiencesellschaft Vs. DCIT [201 1-TII-52-ITAT-MUM-INTL held that royalty received by the Siemens Aktiencesellschaft (taxpayer) was in pursuance of an agreement entered into before 1976 and therefore not covered under Section 115A of the Income-tax Act, 1961 (the Act). Accordingly, the taxpayer was subject to 50 percent tax on such royalties.

Facts of the case

• The tax

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