https://www.taxtmi.com/caselaws?id=769941 A fiscally transparent entity was held entitled to India-USA DTAA benefits where treaty residence conditions were otherwise satisfied, even if tax was levied through its members rather than in the entity's own hands. Domain name registration receipts were held not to be royalty because the assessee merely facilitated registration and did not grant any proprietary right or right to use an asset. Web hosting, web designing, SSL certification and on-demand product receipts were held not to be fees for technical services because the services were standardised, did not transmit technical know-how or skill, and failed the make available test. The additions on treaty denial, royalty and FTS therefore did not survive. en-us Wed, 30 Apr 2025 00:00:00 +0530 Sat, 03 May 2025 08:34:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769941 A fiscally transparent entity was held entitled to India-USA DTAA benefits where treaty residence conditions were otherwise satisfied, even if tax was levied through its members rather than in the entity's own hands. Domain name registration receipts were held not to be royalty because the assessee merely facilitated registration and did not grant any proprietary right or right to use an asset. Web hosting, web designing, SSL certification and on-demand product receipts were held not to be fees for technical services because the services were standardised, did not transmit technical know-how or skill, and failed the make available test. The additions on treaty denial, royalty and FTS therefore did not survive. Case-Laws Income Tax Wed, 30 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769941