https://www.scconline.com/blog/post/2016/07/30/owners-of-intellectual-property-rights-not-based-in-india-not-exigible-to-tax-under-income-tax-act-1961-on-income-accruing-from-transfer-of-such-right/
Owners of intellectual property rights not based in India not exigible to tax under Income Tax Act, 1961 on income accruing from transfer of such right