Held that costs recovered by assessee a non-resident for third party software which was integrated into assessee’s IT infrastructure used for rendering services to an Indian company would be taxable as fees for technical services/Royalty as per DTAA between India and Switzerland. on the facts of the case   neither undiluted benefit of software cost was passed on to RIPL nor did assessee recover amount as it is from RIPL authorities below were fully justified in including Rs. 3.89 crores in total income of assessee and charging it to tax at 10 per cent in parity with assessee suo motu offering Rs. 20.04 crores to tax at same rate.  (AY. 2016-17)