https://www.taxtmi.com/caselaws?id=357088 Treaty-covered service receipts, including loaned service income, committee charges, knowledge pool charges and regional corporate finance charges, are treated as business profits under Article 7 where a MAP arrangement and consistent prior decisions apply. In the absence of an Indian permanent establishment, those receipts are not taxable as royalty or fees for included services under Article 12 or domestic law, except for firm function service charges subject to the MAP-prescribed mark-up. Reimbursement claims require verification of the expenditure's nature and any profit element and are remitted to the Assessing Officer for fresh adjudication. 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, including loaned service income, committee charges, knowledge pool charges and regional corporate finance charges, are treated as business profits under Article 7 where a MAP arrangement and consistent prior decisions apply. In the absence of an Indian permanent establishment, those receipts are not taxable as royalty or fees for included services under Article 12 or domestic law, except for firm function service charges subject to the MAP-prescribed mark-up. Reimbursement claims require verification of the expenditure's nature and any profit element and are remitted to the Assessing Officer for fresh adjudication. Case-Laws Income Tax Wed, 14 Mar 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=357088