https://www.taxtmi.com/caselaws?id=306073 Advisory receipts from home-office allocations were held not to constitute fees for included services under the India-USA treaty because the services did not make available technical knowledge, experience or skill to the Indian affiliate, and the addition was deleted. Chargeback receipts were also treated as reimbursements of actual third-party payments, with no mark-up and no service rendered by the recipient to the Indian entities; even otherwise, the treaty's make available test was not satisfied, so the receipts were not taxable as fees for technical services and the addition was deleted. en-us Wed, 19 Feb 2020 00:00:00 +0530 Sun, 08 Jan 2023 20:15:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306073 Advisory receipts from home-office allocations were held not to constitute fees for included services under the India-USA treaty because the services did not make available technical knowledge, experience or skill to the Indian affiliate, and the addition was deleted. Chargeback receipts were also treated as reimbursements of actual third-party payments, with no mark-up and no service rendered by the recipient to the Indian entities; even otherwise, the treaty's make available test was not satisfied, so the receipts were not taxable as fees for technical services and the addition was deleted. Case-Laws Income Tax Wed, 19 Feb 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306073