https://www.taxtmi.com/caselaws?id=187600 Receipts from services were held not to constitute "included services" under Article 12(4) of the India-US DTAA, following earlier co-ordinate bench decisions on materially similar facts. As the non-resident had no permanent establishment in India, the receipts also could not be taxed as business profits under Article 7. The treaty position therefore excluded Indian taxability on both bases, and the relief granted by the appellate authority was confirmed. en-us Wed, 24 Mar 2010 00:00:00 +0530 Fri, 28 Oct 2016 10:52:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=187600 Receipts from services were held not to constitute "included services" under Article 12(4) of the India-US DTAA, following earlier co-ordinate bench decisions on materially similar facts. As the non-resident had no permanent establishment in India, the receipts also could not be taxed as business profits under Article 7. The treaty position therefore excluded Indian taxability on both bases, and the relief granted by the appellate authority was confirmed. Case-Laws Income Tax Wed, 24 Mar 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=187600