https://www.taxtmi.com/caselaws?id=75808 The AAR applied the India-UK treaty "make available" test and held that centralized support, templates, guidance, coordination and related market-development services did not transfer technical knowledge, experience, skill, know-how or processes to the recipient. On that basis, the receipts were not taxable in India as business profits or otherwise under the treaty. The AAR further held that the same payments did not constitute fees for technical services under section 9(1)(vii) because mere managerial, informational or support services, without independent transfer of technical know-how, do not satisfy the statutory test. The ruling left open the question of arm's length contribution for assessment proceedings. en-us Fri, 19 Mar 2010 00:00:00 +0530 Mon, 03 Aug 2026 15:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=75808 The AAR applied the India-UK treaty "make available" test and held that centralized support, templates, guidance, coordination and related market-development services did not transfer technical knowledge, experience, skill, know-how or processes to the recipient. On that basis, the receipts were not taxable in India as business profits or otherwise under the treaty. The AAR further held that the same payments did not constitute fees for technical services under section 9(1)(vii) because mere managerial, informational or support services, without independent transfer of technical know-how, do not satisfy the statutory test. The ruling left open the question of arm's length contribution for assessment proceedings. Case-Laws Income Tax Fri, 19 Mar 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=75808