https://www.taxtmi.com/caselaws?id=212541 Advisory, consultancy, education and training receipts were held not to be fees for included services because they did not satisfy the treaty "make available" requirement, and incidental use of a name or logo did not convert the contracts into royalty. In the absence of a permanent establishment, the receipts from the Indian entities were therefore not taxable as business profits under the India-USA DTAA. Reimbursements of actual travel and lodging expenses were also not treated as taxable income on the facts found. As no underlying tax liability arose in India, the payer had no obligation to deduct tax at source. en-us Fri, 18 Nov 2011 00:00:00 +0530 Tue, 25 Jun 2013 09:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=212541 Advisory, consultancy, education and training receipts were held not to be fees for included services because they did not satisfy the treaty "make available" requirement, and incidental use of a name or logo did not convert the contracts into royalty. In the absence of a permanent establishment, the receipts from the Indian entities were therefore not taxable as business profits under the India-USA DTAA. Reimbursements of actual travel and lodging expenses were also not treated as taxable income on the facts found. As no underlying tax liability arose in India, the payer had no obligation to deduct tax at source. Case-Laws Income Tax Fri, 18 Nov 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=212541