https://www.taxtmi.com/caselaws?id=466831 Consultancy and support receipts were not fees for included services under Article 12(4)(b) of the India-USA DTAA because the services were advisory or ongoing support in nature and did not make available technical knowledge, skill, experience or know-how to the Indian recipient; the additions were deleted. Cost-to-cost reimbursement of third-party expenses and miscellaneous outlays without markup likewise did not satisfy the treaty conditions for fees for included services, and the additions were deleted. Prior settlement under the Vivad Se Vishwas Scheme did not amount to tacit acceptance of the additions. Subscription fee receipts were not royalty because they represented access to copyrighted material rather than transfer of copyright, so they were not taxable in India. en-us Fri, 22 Aug 2025 00:00:00 +0530 Fri, 20 Feb 2026 20:59:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466831 Consultancy and support receipts were not fees for included services under Article 12(4)(b) of the India-USA DTAA because the services were advisory or ongoing support in nature and did not make available technical knowledge, skill, experience or know-how to the Indian recipient; the additions were deleted. Cost-to-cost reimbursement of third-party expenses and miscellaneous outlays without markup likewise did not satisfy the treaty conditions for fees for included services, and the additions were deleted. Prior settlement under the Vivad Se Vishwas Scheme did not amount to tacit acceptance of the additions. Subscription fee receipts were not royalty because they represented access to copyrighted material rather than transfer of copyright, so they were not taxable in India. Case-Laws Income Tax Fri, 22 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466831