https://www.taxtmi.com/caselaws?id=450936 Under Article 12(4) of the India-USA DTAA, e-publishing, sub-contracting, and related sales and marketing support services were not taxable as fees for included services because they did not make available technical knowledge, experience, skill, know-how, or processes enabling independent future use by the recipient. The connected receipt was therefore treated as outside the scope of taxable FIS. The issues relating to interest under sections 234A and 234B, and refund computation, depended on verification of the extended due date, the actual return-filing date, and the computation sheet, so they required fresh examination and recomputation by the Assessing Officer. en-us Wed, 13 Mar 2024 00:00:00 +0530 Fri, 15 Mar 2024 17:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450936 Under Article 12(4) of the India-USA DTAA, e-publishing, sub-contracting, and related sales and marketing support services were not taxable as fees for included services because they did not make available technical knowledge, experience, skill, know-how, or processes enabling independent future use by the recipient. The connected receipt was therefore treated as outside the scope of taxable FIS. The issues relating to interest under sections 234A and 234B, and refund computation, depended on verification of the extended due date, the actual return-filing date, and the computation sheet, so they required fresh examination and recomputation by the Assessing Officer. Case-Laws Income Tax Wed, 13 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450936