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1990 (12) TMI 51 - HC - Income Tax
Extract:
....... and the U. K. The consideration paid is for an outright transfer of the drawings and designs by the non-resident company and such consideration cannot be termed as royalty. We, therefore, answer the question in this reference in the affirmative and in favour of the assessee. There will be no order s to costs. BHAGABATI PRASAD BANERJEE J. -I agree.