https://www.taxtmi.com/caselaws?id=189000 Consultancy and software access receipts were held not taxable in India as "fees for included services" under Article 12 of the India-US Treaty. The Tribunal relied on its own earlier years' decisions on identical facts, where such payments had already been found outside the treaty definition. The CIT(A) followed those co-ordinate bench rulings and deleted the addition, and no distinguishing feature was shown before the Tribunal to support a different view. The deletion was therefore upheld in favour of the assessee. en-us Fri, 25 Jun 2010 00:00:00 +0530 Fri, 23 Dec 2016 18:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=189000 Consultancy and software access receipts were held not taxable in India as "fees for included services" under Article 12 of the India-US Treaty. The Tribunal relied on its own earlier years' decisions on identical facts, where such payments had already been found outside the treaty definition. The CIT(A) followed those co-ordinate bench rulings and deleted the addition, and no distinguishing feature was shown before the Tribunal to support a different view. The deletion was therefore upheld in favour of the assessee. Case-Laws Income Tax Fri, 25 Jun 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=189000