https://www.taxtmi.com/caselaws?id=376437 Payments for software licences granting only a restricted right to use a copyrighted article, together with allied IT support, were treated as neither royalty nor fees for technical services because no copyright rights or technical knowledge were transferred and the treaty definition was not enlarged by later domestic amendments. Lease line charges were likewise viewed as connectivity or bandwidth facility payments, not royalty, and training fees failed the make available test because no transferable technical knowledge was imparted. Salary reimbursements for seconded expatriates were characterised as deputation-related cost recovery rather than fees for technical services, so no further withholding default arose. Once the primary withholding claims failed, grossing up under section 195A also did not survive. en-us Wed, 23 Jan 2019 00:00:00 +0530 Sat, 06 Dec 2025 16:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=376437 Payments for software licences granting only a restricted right to use a copyrighted article, together with allied IT support, were treated as neither royalty nor fees for technical services because no copyright rights or technical knowledge were transferred and the treaty definition was not enlarged by later domestic amendments. Lease line charges were likewise viewed as connectivity or bandwidth facility payments, not royalty, and training fees failed the make available test because no transferable technical knowledge was imparted. Salary reimbursements for seconded expatriates were characterised as deputation-related cost recovery rather than fees for technical services, so no further withholding default arose. Once the primary withholding claims failed, grossing up under section 195A also did not survive. Case-Laws Income Tax Wed, 23 Jan 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=376437