https://www.taxtmi.com/caselaws?id=767319 Receipts from General Business Support Services were held not to be fees for technical services because the cost contribution arrangement involved managerial support that did not make available technical knowledge, experience, skill, know-how or processes under the treaty; the addition was deleted. Receipts for access to and maintenance of SUN and GSAP software, including licence, Go-Live and application access charges, were held not to be royalty because royalty arises only on use of, or right to use, copyright, not mere use of copyrighted software, and the treaty definition prevailed over the domestic deeming rule; those additions were also deleted. The common issues were thus decided partly in favour of the assessee. en-us Thu, 27 Feb 2025 00:00:00 +0530 Sat, 15 Mar 2025 08:41:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767319 Receipts from General Business Support Services were held not to be fees for technical services because the cost contribution arrangement involved managerial support that did not make available technical knowledge, experience, skill, know-how or processes under the treaty; the addition was deleted. Receipts for access to and maintenance of SUN and GSAP software, including licence, Go-Live and application access charges, were held not to be royalty because royalty arises only on use of, or right to use, copyright, not mere use of copyrighted software, and the treaty definition prevailed over the domestic deeming rule; those additions were also deleted. The common issues were thus decided partly in favour of the assessee. Case-Laws Income Tax Thu, 27 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767319