https://www.taxtmi.com/caselaws?id=236150 Article 12 of the India-USA tax treaty treats technical or consultancy consideration as fees for included services only where the services make available technical knowledge, experience, skill, know-how or processes that the payer can independently apply in future. Technical design bases, plans and blueprints prepared for a power project were characterised as conferring such future-use capability and therefore taxable as fees for included services. Interest for advance-tax default under section 234B does not arise for a US tax resident where the relevant Indian income is subject to tax deduction at source. en-us Wed, 24 Jul 2013 00:00:00 +0530 Fri, 16 Aug 2013 09:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=236150 Article 12 of the India-USA tax treaty treats technical or consultancy consideration as fees for included services only where the services make available technical knowledge, experience, skill, know-how or processes that the payer can independently apply in future. Technical design bases, plans and blueprints prepared for a power project were characterised as conferring such future-use capability and therefore taxable as fees for included services. Interest for advance-tax default under section 234B does not arise for a US tax resident where the relevant Indian income is subject to tax deduction at source. Case-Laws Income Tax Wed, 24 Jul 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=236150