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of The ITAT affirmed the CIT(A) and allowed the appeal of the assessee, holding that amounts received under the Regional Service Agreement constitute business profits under Article 7 of the India-Singapore DTAA and not 'royalty' under s.9(1)(vi)/Article 12. The Tribunal found no transfer or grant of a right to use intangible property, nor any imparting of a corpus of industrial, commercial or scientific experience; services were performed outside India by regional personnel and remunerated on a cost-sharing basis with no PE in India. Accordingly the AO's royalty addition was unsustainable and the receipts are not taxable in India; decision in favour of the assessee is affirmed.
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