https://www.taxtmi.com/caselaws?id=771966 Cross charges for corporate support services were not fees for included services under Article 12(4) of the India-US DTAA because the services were broad support functions and did not make available technical knowledge, experience, skill, know-how or processes to the Indian entities. Cross charges for software and related facilities were not royalty under Article 12(3) because the Indian entities obtained no copyright or equivalent proprietary rights in the software, and payment for use of software or facilities alone was insufficient. On both treaty grounds, the withholding-tax position could not be sustained, and the assessee was entitled to the certificate sought. en-us Tue, 20 May 2025 00:00:00 +0530 Mon, 25 Aug 2025 14:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771966 Cross charges for corporate support services were not fees for included services under Article 12(4) of the India-US DTAA because the services were broad support functions and did not make available technical knowledge, experience, skill, know-how or processes to the Indian entities. Cross charges for software and related facilities were not royalty under Article 12(3) because the Indian entities obtained no copyright or equivalent proprietary rights in the software, and payment for use of software or facilities alone was insufficient. On both treaty grounds, the withholding-tax position could not be sustained, and the assessee was entitled to the certificate sought. Case-Laws Income Tax Tue, 20 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771966