https://www.taxtmi.com/caselaws?id=278204 Under the India-USA DTAA, marketing, sales support and managerial services rendered outside India were not fees for included services because the make available test was not met, while services rendered in India created a service permanent establishment and the attributable income was taxable as business profits. Reimbursement of lease line charges was not royalty because the arrangement was only telecom connectivity and did not place equipment or intellectual property at the payer's disposal. Interest under sections 234B and 234C was not leviable where the non-resident's income was subject to tax deduction at source. Reimbursement and asset acquisition payments were remanded for fresh factual examination. en-us Wed, 14 Mar 2012 00:00:00 +0530 Thu, 17 Jan 2019 16:57:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=278204 Under the India-USA DTAA, marketing, sales support and managerial services rendered outside India were not fees for included services because the make available test was not met, while services rendered in India created a service permanent establishment and the attributable income was taxable as business profits. Reimbursement of lease line charges was not royalty because the arrangement was only telecom connectivity and did not place equipment or intellectual property at the payer's disposal. Interest under sections 234B and 234C was not leviable where the non-resident's income was subject to tax deduction at source. Reimbursement and asset acquisition payments were remanded for fresh factual examination. Case-Laws Income Tax Wed, 14 Mar 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=278204