No income tax on receipt of reimbursement of software license fees from Indian subsidiary

SCA Hygiene Products AB Vs DCIT (ITAT Mumbai) Conclusion: No income tax applicable on receipt of software license fees from an Indian subsidiary as it was reimbursement of software licence fees paid by assessee to a third party, and, therefore, it could not constitute income taxable in the hands of assessee. Held: Assessee was a company incorporated, and fiscally domiciled, in Sweden. It had a subsidiary in India by the name of SCA Hygiene Products India Pvt Ltd (SCA-India). Under a service agreement, assessee was under an obligation to render services, which included “providing hardware and...