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Management fee received from Indian Co. for providing support to carry on business efficiently no taxable as FTS

August 14, 2020[2020] 118 taxmann.com 2 (Mumbai - Trib.)
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INTERNATIONAL TAXATION : Where assessee Singapore company provided IDC service to its India group companies from Singapore which included mail box/website hosting services and appellant only provided service by using its hardware/security devices/personnel and by not use of any Software, nor any embedded/secret software was developed by appellant, revenue received would not be royalty

INTERNATIONAL TAXATION : Where assessee received management fee from Indian company to support it in carrying on business efficiently and in line with business model, policies and best practices and these services did not make available any technical knowledge, skill, know-how or processes to Indian company, such fees would not be fees for technical services

INTERNATIONAL TAXATION : Where referral services/other services were provided by assessee Singapore company to support Indian company in carrying on business and there was no transmission of technical knowledge, experience, skill etc. from assessee to Indian company or its clients, revenue received was not royalty

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