The Delhi Income Tax Appellate Tribunal has ruled on the tax implications of a transfer of technology by a UK resident company to its Indian subsidiary. As part of the transfer of technology agreement, the UK company was required to grant license to use the intellectual property (IP) for the manufacture of goods, deliver related documents and provide reasonable engineer skill for the use of the IP, conduct testing and inspection, and provide other technical assistance. As per the agreement, the UK company assigned personnel to India to provide testing and inspection services and other technical assistance services. The personnel...