Income from Franchise Fees and Consultancy Services Not Considered Royalty Under India-USA DTAA Article 5.4.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Income from franchise fee and consultancy services - Nature of Royalty - whether taxable @ 10% as per India-USA DTAA - No activities are carried out by the by Jubilant on behalf of the assessee. In our view, none of the clause either (a), (b) or (c) of Article-5.4 are applicable on the assessee. - AT....