https://www.taxtmi.com/caselaws?id=440577 Project-specific architectural, master-planning and project management support was examined under Article 12(4)(b) of the India-USA DTAA to determine whether it made available technical knowledge, skill, know-how or a technical design. The Tribunal found that preliminary drawings, conceptual planning and review inputs were confined to a single project and only assisted the EPC contractor; they did not transfer executable technical plans or enable the recipient to apply the technology independently in future work. On that basis, the receipts did not constitute Fees for Included Services and were not taxable in India under that provision. en-us Tue, 18 Jul 2023 00:00:00 +0530 Tue, 27 Jan 2026 11:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=440577 Project-specific architectural, master-planning and project management support was examined under Article 12(4)(b) of the India-USA DTAA to determine whether it made available technical knowledge, skill, know-how or a technical design. The Tribunal found that preliminary drawings, conceptual planning and review inputs were confined to a single project and only assisted the EPC contractor; they did not transfer executable technical plans or enable the recipient to apply the technology independently in future work. On that basis, the receipts did not constitute Fees for Included Services and were not taxable in India under that provision. Case-Laws Income Tax Tue, 18 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=440577