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        Case ID :
        Income Tax

        ITAT held that cost allocations for SUN/SAP software, GST...

        Software Cost Allocations Not Royalty: International Tech Services Payments Exempt from Indian Taxation Under Established Precedent

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                ITAT held that cost allocations for SUN/SAP software, GST scoping, and IT service charges do not constitute royalty or Fees for Technical Services (FTS). The tribunal found these receipts do not involve transfer of technical knowledge, skill, or experience, and therefore cannot be taxed in India. Following precedent from Supreme Court's Engineering Analysis Centre of Excellence case, the tribunal directed the Assessing Officer to delete additions made towards these cost allocations, rejecting revenue's contentions that these payments qualify as taxable technical services or royalty under Article 13 of the tax treaty.
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