Held that reimbursement of software licence fee was held to be not taxable as royalty. Followed earlier year order. (AY. 2016-17)
Essity Hygiene and Health AB v. Dy. CIT (2021) 190 ITD 166 (Mum.)(Trib.)
S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Reimbursement of software licence fee-Not liable to be taxed as royalty-DTAA-India-Swedish. [Art. 12]