TDS not deductible as patent/ copyright not used against royalty paid

Oil and Natural Gas Corporation Limited Vs ITO (ITAT Ahmedabad) Held that TDS not deductible when neither any patent or copyright was used by the assessee against which the royalty was paid nor there was any technical know-how made available to the assessee. Facts- The assessee is Central Public Sector Undertaking. The assessee has entered into an agreement with University of Texas at Austin, USA. The agreement was entered to carry out research activity in collaboration with the assessee for the development of suitable chemical Enhanced Oil Recovery (EOR) formulations for its 5 reservoirs. The...