Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
The key points in the legal document are: Software licensing amounts do not qualify as Fees for Included Services under Article 12(4)(b) of the India-US DTAA, as the 'make available' clause is not satisfied. The non-resident has not made available the technical skill, expertise, or technical know-how used in preparing the commercial information to the assessee. Installation and integration services related to software are merely support services and cannot be taxed as Fees for Included Services when the primary services are not taxable. The assessee's appeal is allowed, following relevant precedents.
The key points in the legal document are: Software licensing amounts do not qualify as Fees for Included Services under Article 12(4)(b) of the India-US DTAA, as the 'make available' clause is not satisfied. The non-resident has not made available the technical skill, expertise, or technical know-how used in preparing the commercial information to the assessee. Installation and integration services related to software are merely support services and cannot be taxed as Fees for Included Services when the primary services are not taxable. The assessee's appeal is allowed, following relevant precedents.
Note: It is a system-generated summary and is for quick reference only.
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