https://www.taxtmi.com/caselaws?id=438516 The court dismissed the Revenue's appeal, ruling in favor of the assessee regarding the interpretation of Article 12(4) of the DTAA between India and the USA. It held that the fees for included services covered both technical and consultancy services, as the term 'services' in plural was used. The services provided were deemed project-specific and not 'made available' for perpetual use, thus not meeting the criteria set by the Revenue. Consequently, the questions of law were resolved in favor of the assessee, with no costs awarded. en-us Mon, 27 Mar 2023 00:00:00 +0530 Fri, 01 Mar 2024 11:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=438516 The court dismissed the Revenue's appeal, ruling in favor of the assessee regarding the interpretation of Article 12(4) of the DTAA between India and the USA. It held that the fees for included services covered both technical and consultancy services, as the term 'services' in plural was used. The services provided were deemed project-specific and not 'made available' for perpetual use, thus not meeting the criteria set by the Revenue. Consequently, the questions of law were resolved in favor of the assessee, with no costs awarded. Case-Laws Income Tax Mon, 27 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=438516