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of <h1>Supreme Court Confirms Payments Not Royalty or Fees for Services u/s 9(1)(vii) in India-USA Tax Case.</h1> The legal dispute involved the characterization of payments made by an Indian company to a non-resident US entity, questioning whether they were 'Royalty' or 'Fee for Included Services' under Section 9(1)(vii) of the Income Tax Act and the India-USA DTAA. The Karnataka High Court upheld the ITAT's decision, determining that the payments did not qualify as royalty or fees for technical services, thus not requiring TDS deduction. The services were rendered in the USA without a permanent establishment in India. The Supreme Court dismissed the Revenue's appeal, affirming the lower courts' rulings, emphasizing the significance of DTAAs in cross-border taxation.
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