The Indian Authority for Advance Rulings (AAR) delivered a ruling dated 18 July 2008 in the case of Dell International Services (India) Pvt. Ltd., Bangalore on whether payment to a non-resident entity for provision of telecom bandwidth services was taxable in India as royalty or fees for included services (FIS) under the India-United States tax treaty (the Treaty). (a) Facts. The Applicant (i.e. Dell International Services (India) Pvt. Ltd.) was part of the Dell group of companies and was engaged in the business of providing call centre, data processing and information technology support services to its group companies. The Applicant's...