https://www.taxtmi.com/caselaws?id=414256 Receipt for software and IT licence costs was held not to be reimbursement because the expenditure was not incurred strictly for and on behalf of the Indian affiliate, and the allocation lacked a clear one-to-one correlation with amounts recovered. It was also held not to be software royalty, as no software licence or copyright rights were transferred or sublicensed; the software was used to support a centralized IT service model. The amount was treated as part of the consideration for IT services rendered to the affiliate, and the attempted bifurcation into taxable and non-taxable components was found artificial. en-us Thu, 21 Oct 2021 00:00:00 +0530 Thu, 03 Mar 2022 16:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=414256 Receipt for software and IT licence costs was held not to be reimbursement because the expenditure was not incurred strictly for and on behalf of the Indian affiliate, and the allocation lacked a clear one-to-one correlation with amounts recovered. It was also held not to be software royalty, as no software licence or copyright rights were transferred or sublicensed; the software was used to support a centralized IT service model. The amount was treated as part of the consideration for IT services rendered to the affiliate, and the attempted bifurcation into taxable and non-taxable components was found artificial. Case-Laws Income Tax Thu, 21 Oct 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=414256