https://www.taxtmi.com/caselaws?id=212965 Reinsurance brokerage or commission received by an international reinsurance intermediary was not taxable as fees for technical services under section 9(1)(vii) of the Income-tax Act read with article 13(4)(c) of the India-UK tax treaty because the services were limited to arranging reinsurance cover and passing communications between parties. No technical knowledge, skill, know-how, process, technical plan or technical design was made available to the Indian insurance companies, so the make available condition was not satisfied. The High Court treated these findings as factual and found no perversity to justify interference under section 260A, leaving the receipts outside FTS treatment. en-us Mon, 23 Apr 2012 00:00:00 +0530 Mon, 20 Jul 2026 11:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=212965 Reinsurance brokerage or commission received by an international reinsurance intermediary was not taxable as fees for technical services under section 9(1)(vii) of the Income-tax Act read with article 13(4)(c) of the India-UK tax treaty because the services were limited to arranging reinsurance cover and passing communications between parties. No technical knowledge, skill, know-how, process, technical plan or technical design was made available to the Indian insurance companies, so the make available condition was not satisfied. The High Court treated these findings as factual and found no perversity to justify interference under section 260A, leaving the receipts outside FTS treatment. Case-Laws Income Tax Mon, 23 Apr 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=212965