https://www.taxtmi.com/caselaws?id=442484 Receipts from market research, strategic research, planning, data collection and client liaison were treated as advisory business-support services, but they did not qualify as fee for included services because they did not make available technical knowledge, experience, skill, knowhow or processes for independent use by the Indian affiliate. Reimbursement of client-related expenses on a cost-to-cost basis was likewise outside Article 12(4)(b), as third-party research costs without mark-up did not acquire taxable character merely because they were routed through the assessee. Both receipts therefore fell outside the treaty provision, and the tax additions were deleted. en-us Tue, 29 Aug 2023 00:00:00 +0530 Sat, 02 Sep 2023 07:51:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=442484 Receipts from market research, strategic research, planning, data collection and client liaison were treated as advisory business-support services, but they did not qualify as fee for included services because they did not make available technical knowledge, experience, skill, knowhow or processes for independent use by the Indian affiliate. Reimbursement of client-related expenses on a cost-to-cost basis was likewise outside Article 12(4)(b), as third-party research costs without mark-up did not acquire taxable character merely because they were routed through the assessee. Both receipts therefore fell outside the treaty provision, and the tax additions were deleted. Case-Laws Income Tax Tue, 29 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=442484