https://www.taxtmi.com/highlights?id=98337 Receipts from title search services were held not to be royalty under Article 12(3) of the India-US DTAA because the provider only supplied extracts of public-domain information and did not transfer specialised know-how, methodology, or any right to use a process. Receipts from marketing support services were also held not to be fees for included services, as the advice and assistance provided did not satisfy the make available test under Article 12(4)(b) read with the Protocol. The corresponding additions were deleted; grounds relating to interest and penalty initiation were dismissed. en-us Thu, 02 Apr 2026 08:50:44 +0530 Thu, 02 Apr 2026 08:50:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=98337 Receipts from title search services were held not to be royalty under Article 12(3) of the India-US DTAA because the provider only supplied extracts of public-domain information and did not transfer specialised know-how, methodology, or any right to use a process. Receipts from marketing support services were also held not to be fees for included services, as the advice and assistance provided did not satisfy the make available test under Article 12(4)(b) read with the Protocol. The corresponding additions were deleted; grounds relating to interest and penalty initiation were dismissed. Highlights Income Tax Thu, 02 Apr 2026 08:50:44 +0530 https://www.taxtmi.com/highlights?id=98337