https://www.taxtmi.com/caselaws?id=207563 Technical support services under an India-Netherlands arrangement were treated as fees for technical services because they involved specialised accounting, finance, human resources, legal support and risk-management assistance, and the treaty "make available" test was satisfied where the recipient could use the knowledge and skill independently after the service ended. The service agreement was read together with the related licence arrangement, so the support was treated as ancillary and subsidiary to the enjoyment of licensed rights. On that basis, the payments were taxable in India, tax had to be withheld under section 195, the Indian recipient was required to file a return, and the transfer pricing provisions in sections 92 to 92F applied. en-us Fri, 09 Dec 2011 00:00:00 +0530 Wed, 03 Dec 2025 13:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=207563 Technical support services under an India-Netherlands arrangement were treated as fees for technical services because they involved specialised accounting, finance, human resources, legal support and risk-management assistance, and the treaty "make available" test was satisfied where the recipient could use the knowledge and skill independently after the service ended. The service agreement was read together with the related licence arrangement, so the support was treated as ancillary and subsidiary to the enjoyment of licensed rights. On that basis, the payments were taxable in India, tax had to be withheld under section 195, the Indian recipient was required to file a return, and the transfer pricing provisions in sections 92 to 92F applied. Case-Laws Income Tax Fri, 09 Dec 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=207563