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.

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