Payment to Foreign healthcare services companies for advising, recommending ,assisting in healthcare projects and for conducting education and training programmes are not royalty

JDIT- OSD(IT) Vs. Harvard Medical International USA (ITAT Mumbai) The payment in question was purely for the purpose of advising, recommending and assisting in relation to healthcare projects. It was also for conducting education and training programmes. It was also for the purpose of review and giving feed back of various aspects and new cardiac hospital to be set up, recommendation on planned patient care delivery system. In page 1 5A to 1 5D of the CIT(A)’s order a summary of the activities undertaken by the assessee for WHL have been given. A perusal of the same shows that the consid...