Payment made in pursuance of Cost Contribution Agreement by various entities of a Group in the R & D activities carried out centrally would not be liable to tax in India: AAR

Facts: ABB Limited (applicant), an Indian company, has various business divisions such as power products and systems, automation systems, process automation and robotics systems. The appellant is a part of the ABB Group, which is a leader in power and automation technologies that enable utility and industry customers to improve performance while lowering environmental impact. As per the ABB Group’s Research & Development (R &D) Policy, all basic R & D for the ABB Group is coordinated and directed through ABB Research Ltd., Zurich (ABB Zurich). ABB entities, who wish to participa...