US-India income tax convention, Article 12: 15 percent on royalties and fees for included services (Convention between the United States and India (1989), Art. 12(2)-(4))

“ii) during the subsequent years, 15 percent of the gross amount of royalties or fees for included services; ... payments of any kind received as a consideration for the use of, or the right to use, any copyright of a literary, artistic, or scientific work, including cinematograph films or work on film, tape or other means of reproduction for use in connection with radio or television broadcasting, any patent, trademark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience ... "fees for included services" means payments of any kind to any person in consideration for the rendering of any technical or consultancy services”

• US-India income tax convention, Article 25: India allows the US tax as a deduction from Indian tax on the same income (Convention between the United States and India (1989), Art. 25(2)(a))

It is shown on its own, not counted into a figure.

Cited in these 2 guides

• Selling Data to US AI Companies From Outside the US
• US Withholding Tax When a Foreign Company Licenses Data

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