https://www.taxtmi.com/caselaws?id=792946 Receipts from product analytics services provided under a SaaS model were treated as neither equipment royalty nor fees for technical services or included services under the Act and the India-USA DTAA, because users only obtained a subscription-based right to access the platform without possession, control, or commercial exploitation of the underlying equipment, software, or intellectual property. The arrangement also did not involve transfer of technology or satisfy the make available test. TDS credit was to be verified and allowed, with related interest and exemption adjustments recomputed consequentially. en-us Wed, 18 Mar 2026 00:00:00 +0530 Sat, 06 Jun 2026 08:42:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792946 Receipts from product analytics services provided under a SaaS model were treated as neither equipment royalty nor fees for technical services or included services under the Act and the India-USA DTAA, because users only obtained a subscription-based right to access the platform without possession, control, or commercial exploitation of the underlying equipment, software, or intellectual property. The arrangement also did not involve transfer of technology or satisfy the make available test. TDS credit was to be verified and allowed, with related interest and exemption adjustments recomputed consequentially. Case-Laws Income Tax Wed, 18 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792946