https://www.taxtmi.com/caselaws?id=469593 Receipts from automated data processing services were held not to be royalty because the arrangement involved outsourced processing work through the provider's own computer systems and infrastructure, with no transfer of any right to use a process, equipment, technology, or know-how to the Indian payer. The receipts were also held not to be fees for technical services because the facility was a standard automated service, lacking constant human intervention and not amounting to specialised, exclusive, or customised technical service. The addition based on characterising the receipts as royalty or fees for technical services was not sustainable, and the assessee succeeded. en-us Mon, 06 Oct 2025 00:00:00 +0530 Tue, 23 Jun 2026 19:00:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469593 Receipts from automated data processing services were held not to be royalty because the arrangement involved outsourced processing work through the provider's own computer systems and infrastructure, with no transfer of any right to use a process, equipment, technology, or know-how to the Indian payer. The receipts were also held not to be fees for technical services because the facility was a standard automated service, lacking constant human intervention and not amounting to specialised, exclusive, or customised technical service. The addition based on characterising the receipts as royalty or fees for technical services was not sustainable, and the assessee succeeded. Case-Laws Income Tax Mon, 06 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469593