https://www.taxtmi.com/caselaws?id=444958 ITAT Mumbai held that Management Service Fees (MSF) received by the assessee are not taxable in India as royalty under the India-Netherlands DTAA. The tribunal found that services including IT support, operational assistance, marketing, quality audits, and engineering services did not involve imparting knowledge, skill, or experience but were routine support activities. Since the MSF represented cost allocation without markup, constituting reimbursements rather than royalty payments, they fell outside Article 12(4) of the DTAA and were not subject to Indian taxation. en-us Tue, 27 Jun 2023 00:00:00 +0530 Thu, 26 Oct 2023 15:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444958 ITAT Mumbai held that Management Service Fees (MSF) received by the assessee are not taxable in India as royalty under the India-Netherlands DTAA. The tribunal found that services including IT support, operational assistance, marketing, quality audits, and engineering services did not involve imparting knowledge, skill, or experience but were routine support activities. Since the MSF represented cost allocation without markup, constituting reimbursements rather than royalty payments, they fell outside Article 12(4) of the DTAA and were not subject to Indian taxation. Case-Laws Income Tax Tue, 27 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444958