1 [ts-45-itat-2020(mum)] - transaction square...skf group taxpayer (sweden) indian companies...

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1 [TS-45-ITAT-2020(Mum)]

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Page 1: 1 [TS-45-ITAT-2020(Mum)] - Transaction Square...SKF Group Taxpayer (Sweden) Indian Companies Agreements between Taxpayer and Indian Companies [Assessment Year (AY) - 2013-14, 2014-15]

1 [TS-45-ITAT-2020(Mum)]

Page 2: 1 [TS-45-ITAT-2020(Mum)] - Transaction Square...SKF Group Taxpayer (Sweden) Indian Companies Agreements between Taxpayer and Indian Companies [Assessment Year (AY) - 2013-14, 2014-15]

SKF Group

Taxpayer (Sweden) Indian Companies

Agreements between Taxpayer and Indian Companies [Assessment Year (AY) - 2013-14, 2014-15]

Trademark License Agreement

•Income of Taxpayer offered to tax as royalty.

Technology License Agreement

•Income of Taxpayer offered to tax as royalty.

I.T. Services Delivery Agreement

•Income of Taxpayer considered as reimbusement of income; under the India-Sweden treaty.

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Page 4: 1 [TS-45-ITAT-2020(Mum)] - Transaction Square...SKF Group Taxpayer (Sweden) Indian Companies Agreements between Taxpayer and Indian Companies [Assessment Year (AY) - 2013-14, 2014-15]

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