https://www.taxtmi.com/caselaws?id=396930 Business support charges recovered on a cost-to-cost basis without mark-up were treated as reimbursement of expenses and not taxable as royalty or fees for technical services. The Tribunal held that acting as a central coordinator for group entities, including arranging insurance, IT support, procurement-related services, BPO processing and administrative inputs, did not amount to rendering managerial, technical or consultancy services. It applied the principle that a coordinated support or facility arrangement, without making technical knowledge available or involving a profit element, falls outside royalty and fees for technical services. The low-end BPO and procurement activities were therefore characterised as commercial coordinating functions, and the receipts were held not taxable. en-us Mon, 20 Jul 2020 00:00:00 +0530 Sat, 25 Jul 2020 10:16:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=396930 Business support charges recovered on a cost-to-cost basis without mark-up were treated as reimbursement of expenses and not taxable as royalty or fees for technical services. The Tribunal held that acting as a central coordinator for group entities, including arranging insurance, IT support, procurement-related services, BPO processing and administrative inputs, did not amount to rendering managerial, technical or consultancy services. It applied the principle that a coordinated support or facility arrangement, without making technical knowledge available or involving a profit element, falls outside royalty and fees for technical services. The low-end BPO and procurement activities were therefore characterised as commercial coordinating functions, and the receipts were held not taxable. Case-Laws Income Tax Mon, 20 Jul 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=396930