https://www.taxtmi.com/caselaws?id=408107 SAP licence fee reimbursements paid on a cost-to-cost basis, without any mark-up or income element, were treated as non-taxable and not assessable as royalty. Consultancy receipts were also held outside the scope of fees for technical services because the services did not make available technical knowledge, skill, or know-how enabling the recipient to perform similar services independently in future. IT support receipts likewise were not taxable as fees for technical services or royalty, as they were neither ancillary to royalty nor sufficient to satisfy the make available test. The additions on all three receipt streams were deleted. en-us Thu, 06 May 2021 00:00:00 +0530 Tue, 01 Jun 2021 08:30:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=408107 SAP licence fee reimbursements paid on a cost-to-cost basis, without any mark-up or income element, were treated as non-taxable and not assessable as royalty. Consultancy receipts were also held outside the scope of fees for technical services because the services did not make available technical knowledge, skill, or know-how enabling the recipient to perform similar services independently in future. IT support receipts likewise were not taxable as fees for technical services or royalty, as they were neither ancillary to royalty nor sufficient to satisfy the make available test. The additions on all three receipt streams were deleted. Case-Laws Income Tax Thu, 06 May 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=408107