https://www.taxtmi.com/caselaws?id=212089 Commission for arranging reinsurance placements for Indian insurers was not taxable as fees for technical services because the intermediary and advisory functions did not make available technical knowledge, experience, skill, know-how or processes to the recipients. The activity was treated as facilitation or brokerage, not treaty-covered consultancy, so the receipts fell outside Article 13(4)(c) of the India-United Kingdom DTAA and section 9(1)(vii) of the Income-tax Act, 1961. Once the principal addition failed, the related royalty-based and interest issues did not survive, and the additional royalty grounds were not entertained as they did not arise from the assessment order. en-us Fri, 24 Feb 2012 00:00:00 +0530 Fri, 24 May 2013 15:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=212089 Commission for arranging reinsurance placements for Indian insurers was not taxable as fees for technical services because the intermediary and advisory functions did not make available technical knowledge, experience, skill, know-how or processes to the recipients. The activity was treated as facilitation or brokerage, not treaty-covered consultancy, so the receipts fell outside Article 13(4)(c) of the India-United Kingdom DTAA and section 9(1)(vii) of the Income-tax Act, 1961. Once the principal addition failed, the related royalty-based and interest issues did not survive, and the additional royalty grounds were not entertained as they did not arise from the assessment order. Case-Laws Income Tax Fri, 24 Feb 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=212089