Receipts doesn’t qualify as FIS under India-USA DTAA as service rendered without transfer of technical know-how

Bain & Company Inc. Vs DCIT (ITAT Delhi)

ITAT Delhi held that services are rendered without transfer of technical knowledge, skill, know-how, etc. and accordingly the receipts doesn’t qualify as FIS (Fees for Included Services) under Article 12(4)(b) of the India – USA Double Taxation Avoidance Agreements (DTAA).

Facts-

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