https://www.taxtmi.com/caselaws?id=466058 Receipts recovered as software charges were treated as cost-to-cost payments for standard third-party software, with no right in copyright or transfer of copyright rights; on that basis, they were not royalty under the Income-tax Act or Article 13 of the India-UK DTAA. Group support, IT-shared services, regional charges, and similar support receipts were found to be routine managerial and administrative reimbursements without any making available of technical knowledge, skill, know-how, or process; they therefore did not qualify as fees for technical services under the Income-tax Act or Article 13. The additions were deleted and the revenue's appeals failed. en-us Fri, 31 Jan 2025 00:00:00 +0530 Tue, 20 Jan 2026 17:20:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466058 Receipts recovered as software charges were treated as cost-to-cost payments for standard third-party software, with no right in copyright or transfer of copyright rights; on that basis, they were not royalty under the Income-tax Act or Article 13 of the India-UK DTAA. Group support, IT-shared services, regional charges, and similar support receipts were found to be routine managerial and administrative reimbursements without any making available of technical knowledge, skill, know-how, or process; they therefore did not qualify as fees for technical services under the Income-tax Act or Article 13. The additions were deleted and the revenue's appeals failed. Case-Laws Income Tax Fri, 31 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466058