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Sum received under Research & Development Cooperation agreement couldn’t be classified as royalty

October 31, 2018[2018] 99 23 (Kolkata - Trib.)

IT/ILT: When assessee did not transfer right to use its research and development by research and development agreement with group companies and group companies were entitled to enjoy certain services, such as product developments, maintenance of product quality, uniform handling, packing, storage and marketing methods, since these services by itself did not result in any use of or right to use and there was no transfer of copyright, there could not be any occasion to hold it as royalty

IT/ILT: Where services covered under Management Support Services Agreement were in area of commercial, accounting, auditing, financial, social and legal matters, human resources, insurance etc., since services provided by assessee to its group companies did not 'make available' technical knowledge/skill/expertise, etc., by providing these services, assessee could not be said to have been 'make available' any knowledge, skill, etc. to fall under preview of FTS
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