https://www.taxtmi.com/caselaws?id=312880 Taxability of cross-border service receipts under the India-USA DTAA depends on proper treaty characterization as royalty or fees for included services. Because the authorities had not examined the receipts with reference to the distinct treaty definitions and relevant case law, and the facts were identical to earlier years already remitted for de novo consideration, the matter was sent back to the Assessing Officer for fresh adjudication after giving the assessee a reasonable opportunity of hearing. en-us Wed, 02 Mar 2016 00:00:00 +0530 Wed, 13 Mar 2024 08:43:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=312880 Taxability of cross-border service receipts under the India-USA DTAA depends on proper treaty characterization as royalty or fees for included services. Because the authorities had not examined the receipts with reference to the distinct treaty definitions and relevant case law, and the facts were identical to earlier years already remitted for de novo consideration, the matter was sent back to the Assessing Officer for fresh adjudication after giving the assessee a reasonable opportunity of hearing. Case-Laws Income Tax Wed, 02 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=312880