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    <title>Market data and secondment reimbursements: associated-enterprise recoveries were not taxable as royalty, included services, or technical services.</title>
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    <description>Market data charges recovered from Indian associated enterprises were not taxable as royalty under the India-USA DTAA, as the facts and legal position matched earlier Tribunal decisions and no distinction was established. The related addition was deleted. Reimbursements of salary and employee-related costs for seconded employees were likewise not treated as fees for included services or fees for technical services under the India-USA DTAA, following an earlier Tribunal ruling on comparable expense recoveries. The addition for employee-related reimbursements was deleted, while interest was to be levied consequentially in accordance with law.</description>
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    <pubDate>Sat, 26 Sep 2026 08:31:02 +0530</pubDate>
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      <title>Market data and secondment reimbursements: associated-enterprise recoveries were not taxable as royalty, included services, or technical services.</title>
      <link>https://www.taxtmi.com/highlights?id=104208</link>
      <description>Market data charges recovered from Indian associated enterprises were not taxable as royalty under the India-USA DTAA, as the facts and legal position matched earlier Tribunal decisions and no distinction was established. The related addition was deleted. Reimbursements of salary and employee-related costs for seconded employees were likewise not treated as fees for included services or fees for technical services under the India-USA DTAA, following an earlier Tribunal ruling on comparable expense recoveries. The addition for employee-related reimbursements was deleted, while interest was to be levied consequentially in accordance with law.</description>
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