No taxes to be withheld from cost apportioned by foreign AE which has no profit element: Kolkata ITAT

IT : Where Netherland based Associated Enterprise had purchased Software on licence from a company (Microsoft) for use by all its Group entities and licence fees paid by it for software to Microsoft was apportioned at actual to all Group entities including assessee-company and share of assessee was worked out which was reimbursed to AE of Netherland on basis of actuals, there was no element of profit involved in transactions representing remittance made towards

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