https://www.taxtmi.com/caselaws?id=429711 Treaty taxability of receipts as fees for included services under Article 12(4) of the India-USA DTAA could not be conclusively determined because the precise nature of services rendered was not established on the record; the ITAT therefore remitted the matter to the Assessing Officer for fresh factual examination. Credit for tax deducted at source on interest income also required verification, so that issue was restored for examination and grant of eligible credit after verification. en-us Tue, 01 Nov 2022 00:00:00 +0530 Thu, 03 Nov 2022 09:06:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=429711 Treaty taxability of receipts as fees for included services under Article 12(4) of the India-USA DTAA could not be conclusively determined because the precise nature of services rendered was not established on the record; the ITAT therefore remitted the matter to the Assessing Officer for fresh factual examination. Credit for tax deducted at source on interest income also required verification, so that issue was restored for examination and grant of eligible credit after verification. Case-Laws Income Tax Tue, 01 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=429711