HC to examine taxability of Philips' management support and R&D receipts from Indian affiliate

Nov 05,2019

Calcutta HC admits Revenue's appeal challenging ITAT order holding that amounts received by assessee (Philips Netherlands) from Indian affiliate under Research and Development Co-operation agreement (RDCA) and Management Support Services Agreement (MSSA) were not taxable as royalty or FTS; ITAT had ruled that the amount received by assessee under RDCA was not for right to use research findings, but in the nature of reimbursements, ITAT had observed that services u...


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