Indian transfer pricing regulations
perspective.
3.2 The assessee entered into Technology Transfer
Agreements with Gamesa Innovation and Technology SL
Unipersonal ('Gamesa Spain') dated ... technology which is not available in
India and for which the assessee is dependent on the AE as a
17
part of the technology transferred
extruded
ceramic honeycombs and extrusion die fabrication technology.
9. ARCI entered into a technology transfer agreement on 18.06.1999
with respondent to transfer the know ... seen that the development of technology ceramic honeycombs
by ARCI was experimental. Terms and conditions of technology transfer
agreement clearly suggest that the Centre
stated that the decision of the Government is to have technology transfer and to have such types of scanners manufactured in our country itself ... been successful over the past 10 years, it also agreed to transfer technology and allow ECIL to indigenize and use the said sub systems
technologies from
Unimed technologies Ltd/MJ Pharmaceuticals Ltd (in short
UTL/MJPL), and UTL/MJPL acquired these technologies from
SPIL.
2. The cost of technologies ... does not indicate/decisive that SPIL sold these technologies to
CARACO. As such these technologies were transferred by
UTL/MJPL from Mumbai/Baroda directly
penalties.
(i) Service Tax of Rs.45,29,167/- on the Technology Transfer fee paid to Whirlpool, USA during April, 2007 to March, 2008 under ... following grounds:
(i) No service tax was paid on the technology transfer fee by the Appellant which was taxable under intellectual property rights service
remedy of `White Labelling', and the consequential `Non-
exclusive technology transfer' licences which were to be given.
W.P.(C) 6797/2020 Page ... Combination. In respect thereof, emphasis is laid on the exclusive
technology transfer license agreement which has to be entered into in terms
of paragraph
which have hedged this transfer and rendered it to be a case on mere transfer, transfer of 'user of technology ... case was not of off the shelf transfer and hence was 'a transfer of user of technology. It is also noticed that this case
which have hedged this transfer and rendered it to be a case on mere transfer, transfer of 'user of technology ... case was not of off the shelf transfer and hence was a transfer of user of technology. It is also noticed that this case
SHAILNDRA
KUMAR
Signing Date:31.03.2026
20:35:50
joint venture or technology transfer/trade-mark agreement in the
same or allied field in India ... foreign investor/
technology supplier and the Indian partner.
ii) Even in cases where the foreign investor has a joint venture or
technology transfer/ trademark agreement
extruded
ceramic honeycombs and extrusion die fabrication technology.
9. ARCI entered into a technology transfer agreement on 18.06.1999
with respondent to transfer the know ... seen that the development of technology ceramic
10
honeycombs by ARCI was experimental. Terms and conditions of
technology transfer agreement clearly suggest that the Centre
