https://www.taxtmi.com/caselaws?id=283763 Payments for management and consultancy support to a non-resident were treated as fees for included services under the India-USA DTAA because the foreign company provided knowledge, expertise, advice, training, and decision-making support across managerial, financial, legal, treasury, and risk functions. The absence of the word "managerial" in the treaty was not decisive where technical knowledge, experience, skill, know-how, or processes were made available, so the receipts were taxable in India. As tax was deductible under section 195, the assessee's withholding obligation was triggered and liability under section 201(1) and 201(1A) followed; the cash-basis argument and reliance on Circular No. 7/2007 were rejected. en-us Mon, 29 Jan 2018 00:00:00 +0530 Fri, 11 Oct 2019 10:29:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=283763 Payments for management and consultancy support to a non-resident were treated as fees for included services under the India-USA DTAA because the foreign company provided knowledge, expertise, advice, training, and decision-making support across managerial, financial, legal, treasury, and risk functions. The absence of the word "managerial" in the treaty was not decisive where technical knowledge, experience, skill, know-how, or processes were made available, so the receipts were taxable in India. As tax was deductible under section 195, the assessee's withholding obligation was triggered and liability under section 201(1) and 201(1A) followed; the cash-basis argument and reliance on Circular No. 7/2007 were rejected. Case-Laws Income Tax Mon, 29 Jan 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=283763