Supply of customized software and enabling client personnel to handle the system amounts to “fees for included services” under the India-US tax treaty

Facts

• The Airport Authority of India (“AAI”” or “the applicant”) entered into a contract with Raytheon Company USA (RC) for “Automation Upgrade for third runway at IGI Airport, New Delhi.
• The contract involves RC supplying hardware, software and providing services in connection with installation. The cost of software was the major component of the contract.
• All the activities under the contract were performed outside India by RC and only some support activities relating to i

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