https://www.taxtmi.com/caselaws?id=301202 Offshore maintenance and support services rendered from outside India to PGCIL were held not to constitute royalty or fees for included services under the India-US DTAA because they did not make available technical knowledge, experience, skill, know-how or processes. Consideration for software licence and related offshore services received from NDPL was also treated as non-taxable as royalty or fees for included services, since the software arrangement involved only a right to use without transfer of copyright and the connected services did not satisfy the make-available test. Interest under section 234B was not leviable for the relevant years, while section 234C interest was consequential. en-us Wed, 24 Nov 2021 00:00:00 +0530 Fri, 18 Mar 2022 21:48:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=301202 Offshore maintenance and support services rendered from outside India to PGCIL were held not to constitute royalty or fees for included services under the India-US DTAA because they did not make available technical knowledge, experience, skill, know-how or processes. Consideration for software licence and related offshore services received from NDPL was also treated as non-taxable as royalty or fees for included services, since the software arrangement involved only a right to use without transfer of copyright and the connected services did not satisfy the make-available test. Interest under section 234B was not leviable for the relevant years, while section 234C interest was consequential. Case-Laws Income Tax Wed, 24 Nov 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=301202