https://www.taxtmi.com/caselaws?id=251230 Management support payments to a US resident company were treated as fees for included services under the India-USA DTAA because the foreign provider's assistance in managerial, financial, legal, treasury and risk-management functions made available technical knowledge, experience, skill and know-how for use in the recipient's own decision-making process. Although managerial services are not named in Article 12(4), their substance brought them within the treaty's technical or consultancy service limb. The consideration was therefore taxable in India, and tax was required to be deducted at source under section 195. en-us Fri, 27 Sep 2013 00:00:00 +0530 Tue, 31 Mar 2015 14:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=251230 Management support payments to a US resident company were treated as fees for included services under the India-USA DTAA because the foreign provider's assistance in managerial, financial, legal, treasury and risk-management functions made available technical knowledge, experience, skill and know-how for use in the recipient's own decision-making process. Although managerial services are not named in Article 12(4), their substance brought them within the treaty's technical or consultancy service limb. The consideration was therefore taxable in India, and tax was required to be deducted at source under section 195. Case-Laws Income Tax Fri, 27 Sep 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=251230