Accrual of Income in India - assessee as a non-resident company ...
License Fees Not Classified as 'Royalty' Under India-Canada DTAA; No Tax for Non-Resident Company.
December 22, 2018
Case Laws Income Tax AT
Accrual of Income in India - assessee as a non-resident company which received licence fees in terms of "Membership and Technology Transfer Agreement" - the receipt cannot be characterized as ‘royalty’ and, therefore, the same is outside the purview of taxation in view of India-Canada DTAA.
View Source