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Income Tax - Highlights / Catch Notes

Home Highlights December 2022 Year 2022 This

Income deemed to accrue or arise in India - the consideration ...


Trademark Licensing Payments Classified as Royalties u/s 9(1)(vi) and India-Turkey Tax Treaty Article 12(3.

December 24, 2022

Case Laws     Income Tax     AT

Income deemed to accrue or arise in India - the consideration received by the assessee for permitting the right to use of brand name/trademark under TLA is nothing else but in the nature of royalties as defined under section 9(1)(vi) read with Article 12(3) of India – Turkey tax treaty. Therefore, we concur with the view expressed by learned DRP. - AT

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