https://www.taxtmi.com/caselaws?id=208368 Technology transfer payments to a Singapore entity were treated as fees for technical services under the India-Singapore DTAA because the arrangement satisfied the make-available test: it transmitted technical knowledge, experience, skill and know-how enabling independent use of the gravity water purification technology, so disallowance under section 40(a)(ia) was upheld. By contrast, payments for public relations, liaison, co-ordination, design, marketing, support, advisory, training and planning functions were not shown on the evidence to be managerial, technical or consultancy services, and no technical know-how was proved to have been made available; the deletions by the CIT(A) were therefore sustained. en-us Fri, 28 Jan 2011 00:00:00 +0530 Mon, 20 Jul 2026 11:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=208368 Technology transfer payments to a Singapore entity were treated as fees for technical services under the India-Singapore DTAA because the arrangement satisfied the make-available test: it transmitted technical knowledge, experience, skill and know-how enabling independent use of the gravity water purification technology, so disallowance under section 40(a)(ia) was upheld. By contrast, payments for public relations, liaison, co-ordination, design, marketing, support, advisory, training and planning functions were not shown on the evidence to be managerial, technical or consultancy services, and no technical know-how was proved to have been made available; the deletions by the CIT(A) were therefore sustained. Case-Laws Income Tax Fri, 28 Jan 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=208368