https://www.taxtmi.com/caselaws?id=216156 Marketing, sales support, account handling and managerial support services rendered by a non-resident were analysed under the India-UK DTAA "make available" test. Those services were held not to transmit technical knowledge, skill or experience to the recipient in a usable form, so they did not qualify as fees for technical services under Article 13(4)(c). Because a service permanent establishment in India was accepted, the receipts were instead examined as business profits attributable under Article 7, and the consequential verification of the withholding rate was treated as proper. en-us Wed, 25 Nov 2009 00:00:00 +0530 Wed, 15 Feb 2017 14:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=216156 Marketing, sales support, account handling and managerial support services rendered by a non-resident were analysed under the India-UK DTAA "make available" test. Those services were held not to transmit technical knowledge, skill or experience to the recipient in a usable form, so they did not qualify as fees for technical services under Article 13(4)(c). Because a service permanent establishment in India was accepted, the receipts were instead examined as business profits attributable under Article 7, and the consequential verification of the withholding rate was treated as proper. Case-Laws Income Tax Wed, 25 Nov 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=216156