Management Service Fees Not "Royalty" Under Article 12(4) of DTAA: No Transfer of Know-How or Experience Involved.

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....Royalty - Taxability of Management Service Fees (MSF) - For rendering of these services, there is no element of imparting any "know how or there is transfer of any knowledge, skill or experience. Thus, we hold that none of the services provided by the assessee in the term of "service agreement" falls within the scope and ambit of "royalty" as defined in Article 12(4) of the DTAA. - AT....