Reopening of assessment and treaty taxation issues admitted for hearing, including royalty and fees for included services questions.

An income tax appeal was admitted on substantial questions of law concerning whether reassessment was validly reopened, whether the receipts were taxable as royalty under the India-US tax treaty, and whether related support services were taxable as fees for included services. The HC directed that the appeal be heard along with connected appeals on the listed date.

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Outcome: The income tax appeal was admitted on substantial questions of law concerning reopening of assessment, taxability as royalty under the India-US tax treaty, and taxability of related support services as fees for included services, and the appeal was directed to be heard along with connected appeals on the listed date.

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