Business Support Charges Not Taxable as Fees or Royalties Under Income Tax Act or DTAA; Considered Cost Reimbursement.

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....Royalty/ Fees for Technical Services - Receipt of Business Support Charges - the receipt of business support charge is not taxable as fees for technical services/royalty under the Act or the relevant DTAA as the same is purely in the nature of reimbursement of cost. - AT....