https://www.taxtmi.com/caselaws?id=768432 Receipts from IT support, data management and related services were treated as non-taxable in India under Article 12(4) of the India-USA DTAA because the services did not satisfy the make available test; they did not transfer technical knowledge, skill, know-how or processes that the recipient could independently apply after the services ended. In the absence of a permanent establishment in India, the receipts were also not taxable as business income. On the TDS credit issue, the record mismatch between Form 15CA and Form 26AS required verification, and eligible credit was to be granted after reconciliation. en-us Wed, 26 Feb 2025 00:00:00 +0530 Mon, 07 Apr 2025 19:03:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768432 Receipts from IT support, data management and related services were treated as non-taxable in India under Article 12(4) of the India-USA DTAA because the services did not satisfy the make available test; they did not transfer technical knowledge, skill, know-how or processes that the recipient could independently apply after the services ended. In the absence of a permanent establishment in India, the receipts were also not taxable as business income. On the TDS credit issue, the record mismatch between Form 15CA and Form 26AS required verification, and eligible credit was to be granted after reconciliation. Case-Laws Income Tax Wed, 26 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768432