The High Court (HC) of Mumbai issued its decision on 8 August 2014, in the case of CIT v. Montedison S.p.A. of Italy (ITR 202 of 1993) that “royalty” income arising from contracts for supply of technical know-how prior to 1 April 1976 was exempt from tax. The court further ruled that the above exemption is equally available to the amalgamated company, when pursuant to an amalgamation/merger, the contracts for supply of technical know-how prior to 1 April 1976 between the amalgamating company and the Indian customers are transferred to the amalgamated company (Taxpayer).