https://www.taxtmi.com/highlights?id=93855 The ITAT affirmed the CIT(A) and allowed the appeal of the assessee, holding that amounts received under the Regional Service Agreement constitute business profits under Article 7 of the India-Singapore DTAA and not "royalty" under s.9(1)(vi)/Article 12. The Tribunal found no transfer or grant of a right to use intangible property, nor any imparting of a corpus of industrial, commercial or scientific experience; services were performed outside India by regional personnel and remunerated on a cost-sharing basis with no PE in India. Accordingly the AO's royalty addition was unsustainable and the receipts are not taxable in India; decision in favour of the assessee is affirmed. en-us Tue, 04 Nov 2025 08:03:33 +0530 Tue, 04 Nov 2025 08:03:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=93855 The ITAT affirmed the CIT(A) and allowed the appeal of the assessee, holding that amounts received under the Regional Service Agreement constitute business profits under Article 7 of the India-Singapore DTAA and not "royalty" under s.9(1)(vi)/Article 12. The Tribunal found no transfer or grant of a right to use intangible property, nor any imparting of a corpus of industrial, commercial or scientific experience; services were performed outside India by regional personnel and remunerated on a cost-sharing basis with no PE in India. Accordingly the AO's royalty addition was unsustainable and the receipts are not taxable in India; decision in favour of the assessee is affirmed. Highlights Income Tax Tue, 04 Nov 2025 08:03:33 +0530 https://www.taxtmi.com/highlights?id=93855