https://www.taxtmi.com/caselaws?id=788509 Treaty residence under the India-USA DTAA depends on liability to tax, not on whether the single-member LLC paid tax in its own hands; fiscally transparent treatment in the United States did not defeat treaty entitlement where income was taxed in the hands of the U.S. resident member. Offshore aircraft engine repair and overhaul receipts were not fees for technical services under section 9(1)(vii) or fees for included services under Article 12(4)(b) because no technical knowledge, skill, know-how or design was made available to the Indian customers for independent future use. The addition was deleted, while penalty was treated as premature and interest as consequential. en-us Wed, 11 Mar 2026 00:00:00 +0530 Tue, 24 Mar 2026 08:12:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788509 Treaty residence under the India-USA DTAA depends on liability to tax, not on whether the single-member LLC paid tax in its own hands; fiscally transparent treatment in the United States did not defeat treaty entitlement where income was taxed in the hands of the U.S. resident member. Offshore aircraft engine repair and overhaul receipts were not fees for technical services under section 9(1)(vii) or fees for included services under Article 12(4)(b) because no technical knowledge, skill, know-how or design was made available to the Indian customers for independent future use. The addition was deleted, while penalty was treated as premature and interest as consequential. Case-Laws Income Tax Wed, 11 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788509