https://www.taxtmi.com/caselaws?id=432480 The High Court upheld the lower authorities' decisions, ruling in favor of the respondent/assessee. It affirmed that the respondent/assessee was the beneficial owner of the fees for branding and management services, entitling them to the tax benefits under Article 12 of the India-USA Double Taxation Avoidance Agreement. The Court rejected the appellant/revenue's claim of a back-to-back arrangement with the holding company, determining that the respondent/assessee had full control over the receipts. en-us Thu, 15 Dec 2022 00:00:00 +0530 Fri, 11 Aug 2023 12:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=432480 The High Court upheld the lower authorities' decisions, ruling in favor of the respondent/assessee. It affirmed that the respondent/assessee was the beneficial owner of the fees for branding and management services, entitling them to the tax benefits under Article 12 of the India-USA Double Taxation Avoidance Agreement. The Court rejected the appellant/revenue's claim of a back-to-back arrangement with the holding company, determining that the respondent/assessee had full control over the receipts. Case-Laws Income Tax Thu, 15 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432480