https://www.taxtmi.com/highlights?id=64687 Income accrued in India - Fee for Technical/Included Services - whether the amount received by the assessee for various services, commonly known as centralized services, will fall within the ambit of FIS under Article 12(4)(a) of the Treaty? - the fee received by the assessee under the Centralized Services Agreement cannot be treated as FIS either under Article 12(4)(a) or 12(4)(b) of the India–US Tax Treaty. As a natural corollary, it can only be treated as business income of the assessee. Hence, in absence of a PE in India, it will not be taxable. - AT en-us Tue, 19 Jul 2022 09:21:46 +0530 Wed, 20 Jul 2022 12:30:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=64687 Income accrued in India - Fee for Technical/Included Services - whether the amount received by the assessee for various services, commonly known as centralized services, will fall within the ambit of FIS under Article 12(4)(a) of the Treaty? - the fee received by the assessee under the Centralized Services Agreement cannot be treated as FIS either under Article 12(4)(a) or 12(4)(b) of the India–US Tax Treaty. As a natural corollary, it can only be treated as business income of the assessee. Hence, in absence of a PE in India, it will not be taxable. - AT Highlights Income Tax Tue, 19 Jul 2022 09:21:46 +0530 https://www.taxtmi.com/highlights?id=64687