https://www.taxtmi.com/caselaws?id=441466 Standard IT support, infrastructure, mailbox, website hosting and maintenance services rendered from France under group agreements were held not to constitute royalty because no licence, right to use software, or other protected intangible was transferred, and no confidential information was shared. General management support fees were also held not to be fees for technical services because the recipient received no technical knowledge, skill, know-how or process enabling independent application. A guarantee fee claim first raised before the DRP was remitted for fresh examination on merits, since appellate authorities may entertain a valid claim not made in the return and the assessee was entitled to be heard. en-us Fri, 04 Aug 2023 00:00:00 +0530 Mon, 17 Mar 2025 10:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=441466 Standard IT support, infrastructure, mailbox, website hosting and maintenance services rendered from France under group agreements were held not to constitute royalty because no licence, right to use software, or other protected intangible was transferred, and no confidential information was shared. General management support fees were also held not to be fees for technical services because the recipient received no technical knowledge, skill, know-how or process enabling independent application. A guarantee fee claim first raised before the DRP was remitted for fresh examination on merits, since appellate authorities may entertain a valid claim not made in the return and the assessee was entitled to be heard. Case-Laws Income Tax Fri, 04 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=441466