Sum paid to foreign vendor for AMC and for repair of machinery isn’t FTS under India-US DTAA

IT/ILT: Where a US company was paid annual maintenance charges (AMC) in connection with rendering annual maintenance services relating to an equipment sold to assessee, it was required to be considered whether so called AMC services rendered constituted 'included services' in sense of article 12(4)(a) to find out whether AMC payment constituted 'fees for included services'