https://www.taxtmi.com/caselaws?id=756652 Valid foreign tax residency certification and liability to tax in the residence State support treaty eligibility under Article 4 of the India-USA DTAA, and a fiscally transparent structure does not by itself defeat that status. On that basis, the US limited liability company was accepted as entitled to treaty benefits. Receipts from domain name registration, web hosting, web designing and SSL certification services were examined against Article 12(4), with the make available test remaining central to whether they qualify as fees for included services. That question was not finally decided on merits and was remanded for fresh adjudication after a speaking order. en-us Mon, 29 Jul 2024 00:00:00 +0530 Wed, 07 Aug 2024 06:44:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756652 Valid foreign tax residency certification and liability to tax in the residence State support treaty eligibility under Article 4 of the India-USA DTAA, and a fiscally transparent structure does not by itself defeat that status. On that basis, the US limited liability company was accepted as entitled to treaty benefits. Receipts from domain name registration, web hosting, web designing and SSL certification services were examined against Article 12(4), with the make available test remaining central to whether they qualify as fees for included services. That question was not finally decided on merits and was remanded for fresh adjudication after a speaking order. Case-Laws Income Tax Mon, 29 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756652