https://www.taxtmi.com/caselaws?id=760876 Receipts from software updates, patches and on-call support services were held not taxable as Fee for Included Services under Article 12(4)(b) of the India-USA DTAA because the revenue failed to show that technical knowledge, skill, experience or processes were made available to the Indian recipient. Separate invoicing for the two service streams and the continued provision of support indicated that no independent capability was transferred. On refund interest under section 244A, the terminal date for computation was not finally decided; the claim was remitted to the Assessing Officer for verification and recomputation in accordance with law. en-us Thu, 17 Oct 2024 00:00:00 +0530 Tue, 29 Oct 2024 09:00:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760876 Receipts from software updates, patches and on-call support services were held not taxable as Fee for Included Services under Article 12(4)(b) of the India-USA DTAA because the revenue failed to show that technical knowledge, skill, experience or processes were made available to the Indian recipient. Separate invoicing for the two service streams and the continued provision of support indicated that no independent capability was transferred. On refund interest under section 244A, the terminal date for computation was not finally decided; the claim was remitted to the Assessing Officer for verification and recomputation in accordance with law. Case-Laws Income Tax Thu, 17 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760876