Customized research advisory service not taxable as Royalty if no transfer of any copyright

Everest Global Inc. Vs DDIT (ITAT Delhi) Facts- The assessee operates as a global services advisory and research company. Assessee assists corporations in developing and implementing leading edge sourcing strategies including captive outsourced and shared services approaches. The assessee is a LLC registered in United States of America and hence entitled to be governed by the provision of the DTAA between entered into between India and USA. AO completed the assessment by making an addition on account of management fee and IC Labour Charges received by the assessee in respect of services offere...