https://www.taxtmi.com/highlights?id=73377 Income taxable in India - Management Support Charges - the fee received by the assessee under the Centralized Services Agreement cannot be treated as FIS either under Article 12(4)(a) or 12(4)(b) of the India–US Tax Treaty. As a natural corollary, it can only be treated as business income of the assessee. Hence, in absence of a PE in India, it will not be taxable. - AT en-us Mon, 04 Dec 2023 08:43:52 +0530 Mon, 04 Dec 2023 08:43:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=73377 Income taxable in India - Management Support Charges - the fee received by the assessee under the Centralized Services Agreement cannot be treated as FIS either under Article 12(4)(a) or 12(4)(b) of the India–US Tax Treaty. As a natural corollary, it can only be treated as business income of the assessee. Hence, in absence of a PE in India, it will not be taxable. - AT Highlights Income Tax Mon, 04 Dec 2023 08:43:52 +0530 https://www.taxtmi.com/highlights?id=73377