https://www.taxtmi.com/caselaws?id=797997 Engineering design review services fall outside fees for included services under Article 12(4) of the India-Canada tax treaty where project-specific drawings, inputs and reviews do not enable the Indian recipient to independently apply technical knowledge, skill, know-how or processes in future projects. They also do not amount to a transferred technical plan or design capable of independent use. The consideration is not royalty under section 9(1)(vi) or Article 12(3) where no right to use intellectual property or designs is granted and the materials remain confined to the particular project. en-us Mon, 03 Aug 2026 00:00:00 +0530 Tue, 01 Sep 2026 08:26:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797997 Engineering design review services fall outside fees for included services under Article 12(4) of the India-Canada tax treaty where project-specific drawings, inputs and reviews do not enable the Indian recipient to independently apply technical knowledge, skill, know-how or processes in future projects. They also do not amount to a transferred technical plan or design capable of independent use. The consideration is not royalty under section 9(1)(vi) or Article 12(3) where no right to use intellectual property or designs is granted and the materials remain confined to the particular project. Case-Laws Income Tax Mon, 03 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797997