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    <title>2020 (1) TMI 1177 - ITAT PUNE</title>
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    <description>Amounts received for granting users rights in off-the-shelf software and for standard facilities and support services were held not taxable as royalty because materially identical receipts in earlier years had already been found outside royalty taxation, and the deletion of the addition followed. The reimbursement claim was not finally adjudicated on the merits; it was remanded for fresh consideration after the assessee was given a reasonable opportunity to place supporting evidence. The difference between Form 3CEB figures and the software receipts was also deleted because, once the underlying software receipts were held not taxable, the differential amount could not be taxed separately.</description>
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      <link>https://www.taxtmi.com/caselaws?id=287206</link>
      <description>Amounts received for granting users rights in off-the-shelf software and for standard facilities and support services were held not taxable as royalty because materially identical receipts in earlier years had already been found outside royalty taxation, and the deletion of the addition followed. The reimbursement claim was not finally adjudicated on the merits; it was remanded for fresh consideration after the assessee was given a reasonable opportunity to place supporting evidence. The difference between Form 3CEB figures and the software receipts was also deleted because, once the underlying software receipts were held not taxable, the differential amount could not be taxed separately.</description>
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