https://www.taxtmi.com/caselaws?id=780685 Receipts under a Regional Service Agreement were held not to be royalty because the foreign enterprise merely performed ongoing managerial, administrative, financial, HR, technology, supplier, and operational services through its own personnel and infrastructure. The recipient obtained only the benefit of those services, without any transfer of a right to use intellectual property, secret formula, process, or proprietary know-how for independent use. The cost-plus remuneration model also supported service character rather than royalty. The receipts were taxable, if at all, only as business profits, and in the absence of a permanent establishment in India, they were not taxable in India. en-us Thu, 30 Oct 2025 00:00:00 +0530 Tue, 04 Nov 2025 08:03:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780685 Receipts under a Regional Service Agreement were held not to be royalty because the foreign enterprise merely performed ongoing managerial, administrative, financial, HR, technology, supplier, and operational services through its own personnel and infrastructure. The recipient obtained only the benefit of those services, without any transfer of a right to use intellectual property, secret formula, process, or proprietary know-how for independent use. The cost-plus remuneration model also supported service character rather than royalty. The receipts were taxable, if at all, only as business profits, and in the absence of a permanent establishment in India, they were not taxable in India. Case-Laws Income Tax Thu, 30 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780685