https://www.taxtmi.com/caselaws?id=402731 SAP licence recoveries received on a cost-to-cost basis from an Indian subsidiary were treated as pure reimbursement with no income element, and therefore not taxable as income. Consultancy for factory project leadership, including planning, coordination, budgeting, reporting and supervision, was not taxed as fees for technical services because the treaty's make available test was not met; no technical knowledge or know-how was transferred for independent future use. IT support services were likewise not taxable as fees for technical services or royalty under the India-Sweden treaty, since they did not make available technical knowledge and were not ancillary to taxable royalty. The additions were deleted. en-us Fri, 08 Jan 2021 00:00:00 +0530 Wed, 03 Mar 2021 17:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=402731 SAP licence recoveries received on a cost-to-cost basis from an Indian subsidiary were treated as pure reimbursement with no income element, and therefore not taxable as income. Consultancy for factory project leadership, including planning, coordination, budgeting, reporting and supervision, was not taxed as fees for technical services because the treaty's make available test was not met; no technical knowledge or know-how was transferred for independent future use. IT support services were likewise not taxable as fees for technical services or royalty under the India-Sweden treaty, since they did not make available technical knowledge and were not ancillary to taxable royalty. The additions were deleted. Case-Laws Income Tax Fri, 08 Jan 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=402731