Multinational Tech Firm Wins Major Tax Battle: Royalty Receipts and Service Charges Deemed Non-Taxable Under Section 9(1)(vi)

The ITAT adjudicated a tax dispute involving multiple service charges, systematically examining the taxability of royalty receipts under section 9(1)(vi) and DTAA Article 12. Following consistent precedents from previous assessment years, the Tribunal comprehensively ruled in favor of the assessee, directing the Assessing Officer to delete additions related to Infrastructure Data Centre (IDC) services, Consumer CRM Development Charges, Other Services Charges (referral fees), Management Service Fee, and Member Login Fees. The Tribunal emphasized the recurring nature of these issues and adherence to prior coordinate bench decisions, ultimately allowing the assessee's appeal and eliminating proposed tax additions across multiple service categories. .....

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