Bombay HC: Underwriting and Selling Commission Not Fees for Technical Services

The Bombay HC held that underwriting commission and selling commission paid to managers did not amount to fees for technical services under the DTAA with the UK. The appeal was allowed in favor of the appellant, setting aside the Tribunal's decision.

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The Bombay High Court admitted the appeal to consider whether underwriting commission and selling commission paid to certain managers amounted to fees for technical services under the DTAA with the UK. The Tribunal's decision was challenged based on this question of law.

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