https://www.taxtmi.com/caselaws?id=444963 Receipts under the India-USA DTAA are taxable as fees for included services only where technical or consultancy services make available technical knowledge, experience, skill, know-how, processes, or a technical plan or design. Industrial Liaison Program receipts were treated as relationship-building and information-access activities and were not taxable as such. Sponsorship assignment receipts were found to involve research outputs and intellectual property arrangements that satisfied the make-available requirement, so taxation was upheld. Coordination or consortium membership receipts were limited to hosting, administration, and facilitation and were not taxable as fees for included services. TDS credit was left for verification by the Assessing Officer and to be granted in accordance with law. en-us Mon, 31 Jul 2023 00:00:00 +0530 Thu, 26 Oct 2023 12:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444963 Receipts under the India-USA DTAA are taxable as fees for included services only where technical or consultancy services make available technical knowledge, experience, skill, know-how, processes, or a technical plan or design. Industrial Liaison Program receipts were treated as relationship-building and information-access activities and were not taxable as such. Sponsorship assignment receipts were found to involve research outputs and intellectual property arrangements that satisfied the make-available requirement, so taxation was upheld. Coordination or consortium membership receipts were limited to hosting, administration, and facilitation and were not taxable as fees for included services. TDS credit was left for verification by the Assessing Officer and to be granted in accordance with law. Case-Laws Income Tax Mon, 31 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444963