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 directe

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