https://www.taxtmi.com/caselaws?id=253115 Cross-border receipts arising under a general service arrangement required examination under the India-USA treaty to determine whether they constituted royalty or fees for included services. The tax authorities had proceeded on conflicting bases and had not analysed the receipts in the proper treaty context or applied the relevant legal tests and case law. As the character of the receipts and the applicable treaty provisions had not been properly assessed, the orders were set aside and the matter was restored for de novo consideration by the assessing officer. en-us Fri, 08 Aug 2014 00:00:00 +0530 Sat, 28 Feb 2015 12:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=253115 Cross-border receipts arising under a general service arrangement required examination under the India-USA treaty to determine whether they constituted royalty or fees for included services. The tax authorities had proceeded on conflicting bases and had not analysed the receipts in the proper treaty context or applied the relevant legal tests and case law. As the character of the receipts and the applicable treaty provisions had not been properly assessed, the orders were set aside and the matter was restored for de novo consideration by the assessing officer. Case-Laws Income Tax Fri, 08 Aug 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=253115