https://www.taxtmi.com/caselaws?id=789028 Receipts for title search services were not royalty under Article 12(3) of the India-US DTAA or section 9(1)(vi), because the work merely collated and provided access to public-domain property information without transferring proprietary experience, know-how, or rights to use commercial information. Receipts for marketing support services were not fees for included services under Article 12(4)(b), because advisory and solicitation functions did not make available technical knowledge, skill, know-how, or processes to the recipient. The additions on both streams were deleted, granting partial relief to the assessee. en-us Mon, 09 Mar 2026 00:00:00 +0530 Thu, 02 Apr 2026 08:50:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789028 Receipts for title search services were not royalty under Article 12(3) of the India-US DTAA or section 9(1)(vi), because the work merely collated and provided access to public-domain property information without transferring proprietary experience, know-how, or rights to use commercial information. Receipts for marketing support services were not fees for included services under Article 12(4)(b), because advisory and solicitation functions did not make available technical knowledge, skill, know-how, or processes to the recipient. The additions on both streams were deleted, granting partial relief to the assessee. Case-Laws Income Tax Mon, 09 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789028