https://www.taxtmi.com/caselaws?id=122807 Under Article 13(4)(c) of the India-UK DTAA, fees for technical services arise only where technical knowledge, experience, skill, know-how or processes are made available, or where there is development and transfer of a technical plan or design. On Project TS 0102, the foreign enterprise's vehicle appraisal, testing, ADAMS modelling and training activities involved creating and sharing a model, documenting it for the Indian company, and training its engineers, so the payment fell within the treaty definition and was taxable. On Project TS 0105, independent evaluation of the Rombo motorcycle did not involve any such making available, so the payment was outside the definition and not taxable. en-us Fri, 18 Sep 2009 00:00:00 +0530 Fri, 17 Aug 2012 13:25:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=122807 Under Article 13(4)(c) of the India-UK DTAA, fees for technical services arise only where technical knowledge, experience, skill, know-how or processes are made available, or where there is development and transfer of a technical plan or design. On Project TS 0102, the foreign enterprise's vehicle appraisal, testing, ADAMS modelling and training activities involved creating and sharing a model, documenting it for the Indian company, and training its engineers, so the payment fell within the treaty definition and was taxable. On Project TS 0105, independent evaluation of the Rombo motorcycle did not involve any such making available, so the payment was outside the definition and not taxable. Case-Laws Income Tax Fri, 18 Sep 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=122807