https://www.taxtmi.com/caselaws?id=432295 Receipts for information technology and administrative support services were not Fees for Included Services under Article 12 of the India-USA DTAA because the services did not make available technical knowledge, experience, skill, know-how or processes to the Indian affiliate for independent future use. The arrangement reflected continuing support and assistance, with no transfer of technology or evidence that the recipient could apply the services on its own after the provider's involvement ended. Mere incidental or enduring advantage was insufficient, so the receipts were not taxable in India on that basis. en-us Fri, 30 Dec 2022 00:00:00 +0530 Mon, 02 Jan 2023 08:38:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=432295 Receipts for information technology and administrative support services were not Fees for Included Services under Article 12 of the India-USA DTAA because the services did not make available technical knowledge, experience, skill, know-how or processes to the Indian affiliate for independent future use. The arrangement reflected continuing support and assistance, with no transfer of technology or evidence that the recipient could apply the services on its own after the provider's involvement ended. Mere incidental or enduring advantage was insufficient, so the receipts were not taxable in India on that basis. Case-Laws Income Tax Fri, 30 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432295