Payments under Regional Service Agreement Not Royalty – ITAT Mumbai Rules in Favour of BCD Travel (Singapore)

ACIT Vs BCD Travel Asia Pacific PTE Limited (ITAT Mumbai)

ITAT Mumbai upheld the CIT(A)’s view that payments received by the Singapore-based assessee from its Indian affiliate under a Regional Service Agreement (RSA) are not taxable as “royalty” u/s 9(1)(vi) or Article 12 of the India–Singapore DTAA.

Tribunal noted that the services—covering finance, HR, supplier coordination, technology, & regional management—were rendered from Singapore on a cost-sharing basis, with no transfer of any confidential know-how or intellectual property. It held

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