Amount received for ‘support services’ cannot be taxed as ‘Fees for Included Services’

Russell Reynolds Associates Inc. Vs DCIT (International Taxation) (ITAT Delhi) Facts- The Appellant, incorporated under the laws of the United States of America, filed its Income-tax return for relevant assessment showing income being royalty income received from Russell Reynolds Associates India Private Limited in terms of ‘Licensing Agreement’ for use of Intellectual Property Rights (‘IPRs’) like trademarks / trade names and ‘Information Technology Licensing Agreement’ for use of databases, etc. as per Article 12(3) of the India- USA DTAA. The Deputy Commissioner passed the asses...