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of The ITAT ruled that receipts from Business Support Services (BSS) should be deleted from the assessee's taxable income, following binding precedent established in the SIMPL case. The Tribunal determined that cost allocation for SUN Maintenance Software and GSAP maintenance charges cannot be treated as royalty under the India-UK DTAA, as these payments represented mere cost allocations without income elements. Similarly, expenses related to GSAP Go-Live and software access licenses were not royalties since they granted only the right to use copyrighted software, not rights to the copyright itself. The cost-to-cost basis of allocation across the group without profit markup further supported the non-taxable nature of these receipts in India.
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