https://www.taxtmi.com/caselaws?id=797231 Subscription-based SaaS receipts from Indian customers did not constitute fees for included services under Article 12(4)(b) of the India-USA tax treaty where the products were standard, automated and non-customised. Customers independently used the SDK, their own data and dashboard-generated reports, without receiving customer-specific development, coding, algorithm configuration or post-sale technical services. Technology is made available only when recipients can independently apply it; access to a product embodying technology is insufficient. Retained source code, algorithms and processes, together with recurring subscriptions, showed no transfer of enduring technical capability. Incidental account management, support and demonstrations merely enabled product use and did not transfer technical knowledge, know-how, processes, plans or designs. en-us Wed, 12 Aug 2026 00:00:00 +0530 Wed, 19 Aug 2026 08:20:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797231 Subscription-based SaaS receipts from Indian customers did not constitute fees for included services under Article 12(4)(b) of the India-USA tax treaty where the products were standard, automated and non-customised. Customers independently used the SDK, their own data and dashboard-generated reports, without receiving customer-specific development, coding, algorithm configuration or post-sale technical services. Technology is made available only when recipients can independently apply it; access to a product embodying technology is insufficient. Retained source code, algorithms and processes, together with recurring subscriptions, showed no transfer of enduring technical capability. Incidental account management, support and demonstrations merely enabled product use and did not transfer technical knowledge, know-how, processes, plans or designs. Case-Laws Income Tax Wed, 12 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797231