https://www.taxtmi.com/caselaws?id=219561 Under the India-US tax treaty, marketing and management fees were examined under Article 12(4)(b), and the services were held not to satisfy the make-available requirement; the treaty therefore treated the India-linked portion as business profits under Article 7, while amounts for services rendered outside India were not taxable in India. Reimbursement of international telecom connectivity charges was treated as a pure pass-through of actual lease-line costs without mark-up, so it did not constitute royalty or taxable income. For a non-resident whose receipts were subject to tax deduction at source, interest under sections 234B and 234C was not leviable where the payer had the primary withholding obligation. en-us Fri, 14 Dec 2012 00:00:00 +0530 Thu, 23 Apr 2015 15:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=219561 Under the India-US tax treaty, marketing and management fees were examined under Article 12(4)(b), and the services were held not to satisfy the make-available requirement; the treaty therefore treated the India-linked portion as business profits under Article 7, while amounts for services rendered outside India were not taxable in India. Reimbursement of international telecom connectivity charges was treated as a pure pass-through of actual lease-line costs without mark-up, so it did not constitute royalty or taxable income. For a non-resident whose receipts were subject to tax deduction at source, interest under sections 234B and 234C was not leviable where the payer had the primary withholding obligation. Case-Laws Income Tax Fri, 14 Dec 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=219561