https://www.taxtmi.com/caselaws?id=468764 Centralized IT support services were not royalty because the arrangement provided only a facility for data centre support, bandwidth management, disaster recovery, backup, offsite storage, and security management, without conferring any right to use equipment or infrastructure. The amended Explanations 5 and 6 to section 9(1)(vi) did not change that characterisation on the facts found. Business support services were also not fees for technical services because they covered functional support in areas such as procurement, legal, tax, finance, human resources, and strategy, but did not make available technical knowledge or enable independent performance by the recipient. The dispute therefore turned on the absence of proprietary use and the absence of a make available element. en-us Mon, 06 Jan 2020 00:00:00 +0530 Wed, 20 May 2026 18:25:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468764 Centralized IT support services were not royalty because the arrangement provided only a facility for data centre support, bandwidth management, disaster recovery, backup, offsite storage, and security management, without conferring any right to use equipment or infrastructure. The amended Explanations 5 and 6 to section 9(1)(vi) did not change that characterisation on the facts found. Business support services were also not fees for technical services because they covered functional support in areas such as procurement, legal, tax, finance, human resources, and strategy, but did not make available technical knowledge or enable independent performance by the recipient. The dispute therefore turned on the absence of proprietary use and the absence of a make available element. Case-Laws Income Tax Mon, 06 Jan 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468764