https://www.taxtmi.com/caselaws?id=432580 Advisory and support service receipts were held not taxable as fees for included services under Article 12 of the Indo-US DTAA because no technical knowledge, skill, know-how, design or process was made available to the recipient, and the cited advance ruling did not displace the factual findings below. In the absence of a permanent establishment, the same receipts were also not taxable as business profits under Article 7. Charge-back receipts and third-party reimbursements were likewise held not taxable as fees for technical services because they represented actual costs incurred abroad and recovered without markup or profit element, with no material showing technical service or benefit to the recipient. en-us Wed, 04 Jan 2023 00:00:00 +0530 Mon, 10 Apr 2023 10:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=432580 Advisory and support service receipts were held not taxable as fees for included services under Article 12 of the Indo-US DTAA because no technical knowledge, skill, know-how, design or process was made available to the recipient, and the cited advance ruling did not displace the factual findings below. In the absence of a permanent establishment, the same receipts were also not taxable as business profits under Article 7. Charge-back receipts and third-party reimbursements were likewise held not taxable as fees for technical services because they represented actual costs incurred abroad and recovered without markup or profit element, with no material showing technical service or benefit to the recipient. Case-Laws Income Tax Wed, 04 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432580