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of <h1>ITAT Bangalore rules payments for lead generation to US-AE not 'royalty' or 'fees,' exempting TDS under India-US DTAA.</h1> The ITAT Bangalore examined whether payments made by an assessee to its US-associated enterprise (US-AE) were categorized as 'royalty' or 'fees for included services' under the India-US DTAA, impacting TDS liability under Section 195 of the Income Tax Act. The court found that the US-AE's services, which focused on lead generation and business facilitation, did not involve transferring technical knowledge or intellectual property. Consequently, the payments did not qualify as 'royalty' or 'fees for included services,' exempting the assessee from TDS obligations. This decision highlights the importance of precise interpretation of tax treaties in international transactions.
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