https://www.taxtmi.com/highlights?id=100615 Recovery of market data charges for third-party database access was held not taxable as royalty under Article 12 of the India-USA DTAA, because the facts matched earlier years and pendency of further appeals was not a valid reason to ignore binding coordinate bench decisions. Reimbursements of seconded employee-related expenses were also held not taxable as Fees for Included Services or Fees for Technical Services, as earlier coordinate bench rulings and a High Court dismissal had already taken the same view and no factual distinction was shown. Both substantive additions were directed to be deleted. en-us Tue, 09 Jun 2026 07:50:17 +0530 Tue, 09 Jun 2026 07:50:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=100615 Recovery of market data charges for third-party database access was held not taxable as royalty under Article 12 of the India-USA DTAA, because the facts matched earlier years and pendency of further appeals was not a valid reason to ignore binding coordinate bench decisions. Reimbursements of seconded employee-related expenses were also held not taxable as Fees for Included Services or Fees for Technical Services, as earlier coordinate bench rulings and a High Court dismissal had already taken the same view and no factual distinction was shown. Both substantive additions were directed to be deleted. Highlights Income Tax Tue, 09 Jun 2026 07:50:17 +0530 https://www.taxtmi.com/highlights?id=100615