https://www.taxtmi.com/caselaws?id=447118 Receipts from business consultancy and reimbursement of expenses were not taxable as fee for included services under Article 12(4)(b) of the India-USA DTAA or section 9(1)(vii), because the record did not show that technical knowledge, experience, skill, know-how or processes were made available to the Indian entity for independent use. Receipts from support services were also not taxable under Article 12(4)(b), as the revenue failed to satisfy the make available condition despite the range of administrative, financial, personnel, marketing, computer and information support functions involved. The assessment additions on these receipts were deleted. en-us Thu, 12 Oct 2023 00:00:00 +0530 Mon, 18 Dec 2023 12:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447118 Receipts from business consultancy and reimbursement of expenses were not taxable as fee for included services under Article 12(4)(b) of the India-USA DTAA or section 9(1)(vii), because the record did not show that technical knowledge, experience, skill, know-how or processes were made available to the Indian entity for independent use. Receipts from support services were also not taxable under Article 12(4)(b), as the revenue failed to satisfy the make available condition despite the range of administrative, financial, personnel, marketing, computer and information support functions involved. The assessment additions on these receipts were deleted. Case-Laws Income Tax Thu, 12 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447118