https://www.taxtmi.com/caselaws?id=357088 Treaty-covered service receipts such as loaned service income, firm function service charges, committee charges, knowledge pool charges and regional corporate finance charges were treated as business profits under Article 7, and were not taxable in India as royalty or fees for included services where no permanent establishment was established; only firm function service charges were subjected to the limited 3% mark-up under the MAP arrangement. Reimbursement additions were not finally decided and were sent back for fresh verification of the expenditure character and any profit element. The note records substantive relief on taxability and remand on reimbursements. en-us Wed, 14 Mar 2018 00:00:00 +0530 Sat, 17 Mar 2018 08:02:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=357088 Treaty-covered service receipts such as loaned service income, firm function service charges, committee charges, knowledge pool charges and regional corporate finance charges were treated as business profits under Article 7, and were not taxable in India as royalty or fees for included services where no permanent establishment was established; only firm function service charges were subjected to the limited 3% mark-up under the MAP arrangement. Reimbursement additions were not finally decided and were sent back for fresh verification of the expenditure character and any profit element. The note records substantive relief on taxability and remand on reimbursements. Case-Laws Income Tax Wed, 14 Mar 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=357088