https://www.taxtmi.com/caselaws?id=795986 Passenger system solution receipts from automated reservation and related services are not fees for included services under Article 12 of the India-USA Double Taxation Avoidance Agreement where customers receive only remote access to software and data-centre services. The arrangement does not transfer software, technology, technical knowledge, skill, know-how, process, technical plan or technical design, nor does it enable customers to apply the technology independently. Accordingly, the receipts are not taxable in India as fees for included services. en-us Wed, 29 Apr 2026 00:00:00 +0530 Thu, 30 Jul 2026 08:52:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795986 Passenger system solution receipts from automated reservation and related services are not fees for included services under Article 12 of the India-USA Double Taxation Avoidance Agreement where customers receive only remote access to software and data-centre services. The arrangement does not transfer software, technology, technical knowledge, skill, know-how, process, technical plan or technical design, nor does it enable customers to apply the technology independently. Accordingly, the receipts are not taxable in India as fees for included services. Case-Laws Income Tax Wed, 29 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795986