R Ltd a German company which is non-resident in India earned...

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R Ltd, a German company, which is non-resident in India, earned the following income by way of fee for technical services. Advice about the taxability of such income in the hands of R Ltd in India.
1. Government of India paid Rs. 20,00,000 under an agreement, to be used for a project in India.
2. S Ltd, an Indian company, paid Rs. 30,00,000 for the know-how to be used in India.
3. Y Ltd, an Indian company, paid Rs. 40,00,000 for know-how acquired in Germany to be used in China.
4. Z Ltd, a non-resident company paid Rs. 24,00,000 for acquiring a know-how to be used in India for carrying on certain manufacturing business.
Select the correct answer using the options given below

A. 1 and 2 Taxable

B. Only 1 Taxable

C. 1, 2 and 4 Taxable

D. 1, 2 and 3 Taxable

Answer: Option C

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