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2012 (2) TMI 555 - AT - Income TaxNature of payment - payments were made to six non-resident entities - purely on account of services or nature of royalty - Held that:- As transactions in respect of which the impugned payments were made was purely on account of services and there is no transfer of right to use the goods. In the result, it is held that the Assessing Officer was not justified in treating the payment as royalty and invoking the provisions of sec. 195. See CIT Vs. Godavari Devi Saraf [Smt] [1977 (9) TMI 24 - BOMBAY High Court ]
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