Section 9 of the Income Tax Act, 1961 — Income — Income deemed to accrue to arise in India — Payment made by assessee to a foreign company for supplying drawings, designs, specifications, processes and all other relevant detail in order to manufacture two wheelers in India was brought to tax as royalty by revenue authorities. in view of fact that even though by entering into agreement and by supplying necessary material said foreign entity authorized its actual use, yet actual use would start only when production and sale commenced and that would be stage at which royalty would be payable and thus, impugned order passed by authorities below was to be set aside — Majestic Auto Ltd. vs. Commissioner of income tax [2019] 267 Taxman 252 (Punjab & Haryana)