https://www.taxtmi.com/caselaws?id=764387 A fiscally transparent LLC was treated as entitled to India-USA treaty benefits because treaty eligibility turned on liability to tax, not actual foreign tax payment, and a valid tax residency certificate supported access to relief. Domain name registration receipts were not royalty because a registrar only facilitates registration and does not grant a right to use its property or transfer such a right. Web hosting, web designing, SSL certification and on-demand product receipts were not fees for technical services or fees for included services, as the services were standardised and did not make available technical knowledge, skill, know-how or processes. The additions were deleted. en-us Wed, 01 Jan 2025 00:00:00 +0530 Tue, 03 Jun 2025 15:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764387 A fiscally transparent LLC was treated as entitled to India-USA treaty benefits because treaty eligibility turned on liability to tax, not actual foreign tax payment, and a valid tax residency certificate supported access to relief. Domain name registration receipts were not royalty because a registrar only facilitates registration and does not grant a right to use its property or transfer such a right. Web hosting, web designing, SSL certification and on-demand product receipts were not fees for technical services or fees for included services, as the services were standardised and did not make available technical knowledge, skill, know-how or processes. The additions were deleted. Case-Laws Income Tax Wed, 01 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764387