TDS U/s. 194J not deductible on Payment for outright purchase of copyright and technical know-how

Pidilite Industries Ltd. Vs ITO (ITAT Mumbai)

We find merit in the argument of the assessee for the reason that on perusal of deed of assignment of copyrights and technical knowhow, we find that the assessee has purchased copyrights with exclusive right and interest. Therefore, we are of the considered view that payment made by the assessee for outright purchase of copyrights and technical knowhow does not constitute royalty within the meaning of royalty as defined in section 9(1)(vii) and not liable for TDS u/s 194J of the

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