https://www.taxtmi.com/caselaws?id=233379 IT support services such as help desk, user administration, networking and data-centre support were held not to satisfy the India-Australia DTAA "make available" test because they only assisted the recipients and did not transfer technical knowledge, skill, know-how or process enabling independent use. On that basis, the receipts were not taxable in India as fees for technical services under Article 12 or section 9(1)(vii), and they were also not royalty. The addition was therefore deleted in favour of the assessee. en-us Thu, 31 Jan 2013 00:00:00 +0530 Mon, 25 Aug 2025 14:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=233379 IT support services such as help desk, user administration, networking and data-centre support were held not to satisfy the India-Australia DTAA "make available" test because they only assisted the recipients and did not transfer technical knowledge, skill, know-how or process enabling independent use. On that basis, the receipts were not taxable in India as fees for technical services under Article 12 or section 9(1)(vii), and they were also not royalty. The addition was therefore deleted in favour of the assessee. Case-Laws Income Tax Thu, 31 Jan 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=233379