https://www.taxtmi.com/caselaws?id=793119 Receipts recovered on a cost-allocation basis for access to third-party market databases were held not to be royalty under Article 12 of the India-USA DTAA, because they did not involve use of, or a right to use, intellectual property or information. Reimbursements of employee-related expenses for seconded personnel were also held not to constitute Fees for Included Services or Fees for Technical Services under the same treaty, following binding coordinate bench and High Court precedent. The corresponding additions were deleted on both substantive issues, while the remaining ground was not adjudicated on merits, resulting in partial relief to the assessee. en-us Fri, 05 Jun 2026 00:00:00 +0530 Tue, 09 Jun 2026 07:50:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793119 Receipts recovered on a cost-allocation basis for access to third-party market databases were held not to be royalty under Article 12 of the India-USA DTAA, because they did not involve use of, or a right to use, intellectual property or information. Reimbursements of employee-related expenses for seconded personnel were also held not to constitute Fees for Included Services or Fees for Technical Services under the same treaty, following binding coordinate bench and High Court precedent. The corresponding additions were deleted on both substantive issues, while the remaining ground was not adjudicated on merits, resulting in partial relief to the assessee. Case-Laws Income Tax Fri, 05 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793119