https://www.taxtmi.com/highlights?id=81812 The key points in the legal document are: Software licensing amounts do not qualify as Fees for Included Services under Article 12(4)(b) of the India-US DTAA, as the 'make available' clause is not satisfied. The non-resident has not made available the technical skill, expertise, or technical know-how used in preparing the commercial information to the assessee. Installation and integration services related to software are merely support services and cannot be taxed as Fees for Included Services when the primary services are not taxable. The assessee's appeal is allowed, following relevant precedents. en-us Mon, 30 Sep 2024 13:45:08 +0530 Mon, 30 Sep 2024 13:45:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=81812 The key points in the legal document are: Software licensing amounts do not qualify as Fees for Included Services under Article 12(4)(b) of the India-US DTAA, as the 'make available' clause is not satisfied. The non-resident has not made available the technical skill, expertise, or technical know-how used in preparing the commercial information to the assessee. Installation and integration services related to software are merely support services and cannot be taxed as Fees for Included Services when the primary services are not taxable. The assessee's appeal is allowed, following relevant precedents. Highlights Income Tax Mon, 30 Sep 2024 13:45:08 +0530 https://www.taxtmi.com/highlights?id=81812