Reimbursement Expenses with 10% Markup Classified as "Royalty" and "Fee for Services"; Remanded for Treaty Review.

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Full Text of the Document

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....Consideration received in nature of reimbursement expenses along with mark up @ 10% - “royalty” and “Fee for included services” in equal proportion – matter has not been examined in the context of Indo-US treaty - matter remanded back - AT....