TMI BlogTaxability of receipts - Royalty / Fee for technical services - Switzerland based non-resident assessee...Taxability of receipts - Royalty / Fee for technical services - Switzerland based non-resident assessee from its Indian affiliate - Cumulative satisfaction of both the conditions is essential for constituting 'reimbursement'. If one of them is lacking, the test of reimbursement fails. We are instantly confronted with a situation in which both the conditions are failing. Neither the undiluted benefit of the software cost was passed on to RIPL nor did the assessee recover the amount as it is from ..... ..... X X X X Extracts X X X X X X X X Extracts X X X X
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