https://www.taxtmi.com/caselaws?id=262024 Receipts under consulting, award, education, teaching and reimbursement arrangements were treated as non-taxable in India because identical treaty-based payments had earlier been found not to constitute fee for included services or royalty, and nothing was made available to the Indian entities under the Indo-US DTAA. The Tribunal also relied on the absence of a permanent establishment in India, so the receipts could not be taxed as business profits. Reimbursement followed the tax character of the main receipts, and the interest adjustment was consequential. The additions were deleted. en-us Fri, 03 Jul 2015 00:00:00 +0530 Mon, 17 Aug 2015 12:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=262024 Receipts under consulting, award, education, teaching and reimbursement arrangements were treated as non-taxable in India because identical treaty-based payments had earlier been found not to constitute fee for included services or royalty, and nothing was made available to the Indian entities under the Indo-US DTAA. The Tribunal also relied on the absence of a permanent establishment in India, so the receipts could not be taxed as business profits. Reimbursement followed the tax character of the main receipts, and the interest adjustment was consequential. The additions were deleted. Case-Laws Income Tax Fri, 03 Jul 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=262024