Support services and reimbursement of expenses not taxable in India in terms of India-USA DTAA

Russell Reynolds Associates Inc. Vs DCIT (International Taxation) (ITAT Delhi) ITAT Delhi held that both support services and reimbursement of expenses are not in nature of Fees for Included Services (FIS) under India – USA DTAA and hence not taxable in India. Facts- The assessee, a non-resident corporate entity, offered the royalty income received from its Indian subsidiary under Licensing Agreement towards the use of Intellectual Property Rights (IPR). However, the Company did not offer the amount received towards support services and reimbursement of expenses pleadings that they are not t...