IT/ILT : Assessee was a tax resident of the Netherlands and was engaged in the business of lighting, consumer electronics, medical systems, etc. The assessee did not have a permanent establishment in India. The assessee had entered into Research and Development Cooperation agreement (RDCA) with Philips India (PEIL). The assessee had took the position that the said receipts are not taxable in India in view of Article 12 of the India-Netherlands Double Taxation Avoidance Agreement (DTAA)
from www.taxmann.com Latest Case Laws https://www.taxmann.com/topstories/101010000000184833/sum-received-under-research-development-cooperation-agreement-couldn’t-be-classified-as-royalty.aspx
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