Disallowance of R & D units purchased as per Technical License ...

R&D Units Purchase Under Technical License Agreement Not Considered Royalty; No Disallowance Warranted for Equipment Acquisition. &D.

July 22, 2019

Case Laws Income Tax AT

Disallowance of R & D units purchased as per Technical License Agreement - when the assessee has purchased a product in order to carry out improvements in its technology for future development and its sales thereafter, then such purchases cannot be said to be payment of royalty - the payment was not for use or use of any technology but for purchase of equipment for R&D purpose - no disallowance

View Source

← Previous Next →

Disallowance of R & D units purchased as per Technical License ...

R&D Units Purchase Under Technical License Agreement Not Considered Royalty; No Disallowance Warranted for Equipment Acquisition. &D.

July 22, 2019

Case Laws Income Tax AT

You may also like:

ITAT adjudicated two key tax issues: (1) repairs and maintenance expenditure disallowance was restricted to 10% after reviewing submitted ledger accounts, upholding...

The case revolves around the taxation of income earned by the assessee from licensing software to Indian customers under the India-USA Double Taxation Avoidance...

The Commissioner of Income Tax (CIT) invoked Section 263 to revise the Assessing Officer's (AO) order, disallowing the amount paid on termination of an agreement,...

Royalty payments under a Licence and Technical Assistance Agreement were not addable to the transaction value of imported goods. The agreement covered transfer of...

The CESTAT held that a "deemed sale" under Article 366(29A)(d) of the Constitution had occurred when the appellant granted the right to use the brewery license to...

Estimation of income - bogus purchases - case of bogus bills arranged from the entities and diamonds purchased from somewhere else at a lower cost - The ITAT noted the...

The expenditure incurred by the assessee towards royalty and fee for technical assistance in pursuance of the licence agreement were revenue expenditure and not capital...

The ITAT addressed the taxability of software license receipts as royalty under the India-US Tax Treaty. The case involved a foreign company selling software licenses to...

Levy of service tax - deemed sale - right to use component of the Trademark License Agreement - in the case of the Trademark License Agreement an exclusive license to...

Disallowance u/s 40 (a) (iib) - payment of Gallonage Fee, Licence fee, Shop rental (Kist) and Surcharge on Sales Tax - the levy of Gallonage Fee with respect to the...

Disallowance of expenditure as capital expenditure being 25% of royalty amount paid - it cannot be said that the Sweden Company had relinquished its command over the...

Transactions under a software license agreement - The license charges earned by assessee was not liable to be treated as royalty.

Estimation of income - Bogus purchases - The doubt, if any, is only with regard to the source of purchases. In such circumstances, the entire purchases cannot disallowed....

Application of section 115A or DTAA separately for one sources of income covered by different agreements - From perusal of the aforesaid explanatory notes, it is evident...

Disallowance of payments made for royalty and technical know-how received - Accepted Most appropriate method for benchmarking the manufacturing segment as TNNM -...

Quick Updates: