https://www.taxtmi.com/caselaws?id=786935 Consultancy and support service receipts were held not taxable as fees for included services under the India-USA DTAA because the services were advisory or support in nature and did not satisfy the make available test under Article 12(4). Subscription fees for access to the NPS Prism Platform were held not to be royalty under the Act or the DTAA because access to a platform does not, by itself, confer any right to use copyright. A declaration under the Vivad Se Vishwas Scheme was stated not to amount to tacit acceptance of taxability in later years. TDS credit on interest income required verification of supporting proof, with corresponding income to be taxed in computing the correct liability. en-us Wed, 18 Feb 2026 00:00:00 +0530 Mon, 23 Feb 2026 17:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786935 Consultancy and support service receipts were held not taxable as fees for included services under the India-USA DTAA because the services were advisory or support in nature and did not satisfy the make available test under Article 12(4). Subscription fees for access to the NPS Prism Platform were held not to be royalty under the Act or the DTAA because access to a platform does not, by itself, confer any right to use copyright. A declaration under the Vivad Se Vishwas Scheme was stated not to amount to tacit acceptance of taxability in later years. TDS credit on interest income required verification of supporting proof, with corresponding income to be taxed in computing the correct liability. Case-Laws Income Tax Wed, 18 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786935