https://www.taxtmi.com/caselaws?id=437737 Under the India-US DTAA, project administration and related campus support services were not Fees for Included Services because the recipient was not shown to have been made able to apply technical knowledge, experience, skill, know-how or processes independently; the addition was deleted. Recoveries for market data and database access were not royalty because they reflected access to third-party information without transfer of copyright, technology, server control, or exploitable technical rights, and the reimbursement character of the charges supported non-taxability; the addition was deleted. Interest under section 234A and related credit or carry-forward matters were remanded for verification, while penalty initiation was treated as premature. en-us Mon, 08 May 2023 00:00:00 +0530 Sat, 13 May 2023 08:04:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=437737 Under the India-US DTAA, project administration and related campus support services were not Fees for Included Services because the recipient was not shown to have been made able to apply technical knowledge, experience, skill, know-how or processes independently; the addition was deleted. Recoveries for market data and database access were not royalty because they reflected access to third-party information without transfer of copyright, technology, server control, or exploitable technical rights, and the reimbursement character of the charges supported non-taxability; the addition was deleted. Interest under section 234A and related credit or carry-forward matters were remanded for verification, while penalty initiation was treated as premature. Case-Laws Income Tax Mon, 08 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=437737