https://www.taxtmi.com/highlights?id=39507 Income from franchise fee and consultancy services - Nature of Royalty - whether taxable @ 10% as per India-USA DTAA - No activities are carried out by the by Jubilant on behalf of the assessee. In our view, none of the clause either (a), (b) or (c) of Article-5.4 are applicable on the assessee. - AT en-us Mon, 21 May 2018 12:39:14 +0530 Mon, 21 May 2018 12:39:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=39507 Income from franchise fee and consultancy services - Nature of Royalty - whether taxable @ 10% as per India-USA DTAA - No activities are carried out by the by Jubilant on behalf of the assessee. In our view, none of the clause either (a), (b) or (c) of Article-5.4 are applicable on the assessee. - AT Highlights Income Tax Mon, 21 May 2018 12:39:14 +0530 https://www.taxtmi.com/highlights?id=39507