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The ITAT ruled that receipts for services rendered under the Intra Group Service Agreement do not constitute Fees for Technical Services (FTS) under Article 13(4) of the India-UK DTAA, following previous tribunal decisions for AY 2018-19 and 2019-20. Similarly, advisory services provided to RCIPL-including identifying potential buyers, supporting presentation preparation, coordinating marketing, and advising on transaction options-did not satisfy the "make available" clause as they did not transfer technical knowledge, know-how, or skills. The Tribunal found that neither the Assessing Officer nor the DRP adequately reasoned how these services met the "make available" requirement. Consequently, both service fees were held not taxable in India.
The ITAT ruled that receipts for services rendered under the Intra Group Service Agreement do not constitute Fees for Technical Services (FTS) under Article 13(4) of the India-UK DTAA, following previous tribunal decisions for AY 2018-19 and 2019-20. Similarly, advisory services provided to RCIPL-including identifying potential buyers, supporting presentation preparation, coordinating marketing, and advising on transaction options-did not satisfy the "make available" clause as they did not transfer technical knowledge, know-how, or skills. The Tribunal found that neither the Assessing Officer nor the DRP adequately reasoned how these services met the "make available" requirement. Consequently, both service fees were held not taxable in India.
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