OrbitaxTreaty between India and Australia – Indian decision that data processing costs neither taxable as "royalty" nor "business profit"
|Treaty Development|India-Australia
The Indian Income Tax Appellate Tribunal (ITAT) delivered a ruling dated 13 October 2006 in the case of Kotak Mahindra Primus Ltd. v. Deputy Director of Income Tax ([2007] 11 SOT 578(Mum.)) on whether payments for data processing costs was taxable in India under the India-Australia tax treaty (the Tax Treaty).
(a) Facts. The Appellant (i.e. Kotak Mahindra Prim…
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