https://www.taxtmi.com/caselaws?id=446769 Receipts under the Industrial Liaison Program and Co-ordination Membership Agreement were not taxable as Fees for Included Services under Article 12 of the India-USA DTAA because the activities were limited to relationship-building, administrative coordination, and access facilitation without making available technical knowledge, skill, know-how, or a technical plan or design. By contrast, Sponsorship Assignment receipts were taxable because the assessee undertook specific research and delivered reports and related rights that made available technical know-how and an enduring technology benefit to the sponsor. TDS credit was directed to be verified and allowed in accordance with law. en-us Mon, 30 Oct 2023 00:00:00 +0530 Sat, 09 Dec 2023 12:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446769 Receipts under the Industrial Liaison Program and Co-ordination Membership Agreement were not taxable as Fees for Included Services under Article 12 of the India-USA DTAA because the activities were limited to relationship-building, administrative coordination, and access facilitation without making available technical knowledge, skill, know-how, or a technical plan or design. By contrast, Sponsorship Assignment receipts were taxable because the assessee undertook specific research and delivered reports and related rights that made available technical know-how and an enduring technology benefit to the sponsor. TDS credit was directed to be verified and allowed in accordance with law. Case-Laws Income Tax Mon, 30 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446769