Royalty - Taxability of Management Service Fees (MSF) - For ...
Income Tax
October 27, 2023
Royalty - Taxability of Management Service Fees (MSF) - For rendering of these services, there is no element of imparting any "know how or there is transfer of any knowledge, skill or experience. Thus, we hold that none of the services provided by the assessee in the term of "service agreement" falls within the scope and ambit of "royalty" as defined in Article 12(4) of the DTAA. - AT
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