Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
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Repair and overhaul payments to non-residents were not chargeable as fees for technical services under the applicable DTAA because the make available condition was not shown to be satisfied. In the absence of technical knowledge, know-how or skill being made available for independent future use, no tax deduction obligation arose under section 195, and the disallowance under section 40(a)(i) could not be sustained. The Tribunal followed its earlier coordinate Bench decision in the assessee's own case and deleted the disallowance.
Repair and overhaul payments to non-residents were not chargeable as fees for technical services under the applicable DTAA because the make available condition was not shown to be satisfied. In the absence of technical knowledge, know-how or skill being made available for independent future use, no tax deduction obligation arose under section 195, and the disallowance under section 40(a)(i) could not be sustained. The Tribunal followed its earlier coordinate Bench decision in the assessee's own case and deleted the disallowance.
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