https://www.taxtmi.com/caselaws?id=239338 The Tribunal allowed the Assessee's appeal, ruling that the receipts from various entities were not taxable in India as "Fees for Included Services" or "Royalty," and the reimbursement of expenses was also not taxable. The Revenue's appeal was dismissed, confirming that no interest under section 234B was leviable. The judgment highlighted the significance of the nature of services and the absence of a Permanent Establishment in determining taxability under the Indo-U.S. DTAA. en-us Fri, 22 Feb 2013 00:00:00 +0530 Thu, 07 Jan 2016 13:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=239338 The Tribunal allowed the Assessee's appeal, ruling that the receipts from various entities were not taxable in India as "Fees for Included Services" or "Royalty," and the reimbursement of expenses was also not taxable. The Revenue's appeal was dismissed, confirming that no interest under section 234B was leviable. The judgment highlighted the significance of the nature of services and the absence of a Permanent Establishment in determining taxability under the Indo-U.S. DTAA. Case-Laws Income Tax Fri, 22 Feb 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=239338