https://www.taxtmi.com/caselaws?id=421396 Managerial support and manpower supply payments were not taxable as fees for included services under the India-USA DTAA because the arrangements did not satisfy the "make available" test in Article 12(4)(b); the recipient obtained support and personnel, but no technical knowledge, skill, know-how or processes capable of independent future use. Receipts from database subscriptions and customised research advisory were not royalty because they involved only use of published research materials or provision of advisory outputs, with no transfer of copyright or database rights. For the same non-resident payer, interest under sections 234B and 234C was not chargeable where tax, if any, was deductible at source by the Indian payer. en-us Wed, 30 Mar 2022 00:00:00 +0530 Sat, 23 Apr 2022 08:34:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=421396 Managerial support and manpower supply payments were not taxable as fees for included services under the India-USA DTAA because the arrangements did not satisfy the "make available" test in Article 12(4)(b); the recipient obtained support and personnel, but no technical knowledge, skill, know-how or processes capable of independent future use. Receipts from database subscriptions and customised research advisory were not royalty because they involved only use of published research materials or provision of advisory outputs, with no transfer of copyright or database rights. For the same non-resident payer, interest under sections 234B and 234C was not chargeable where tax, if any, was deductible at source by the Indian payer. Case-Laws Income Tax Wed, 30 Mar 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=421396