https://www.taxtmi.com/caselaws?id=242670 Fees for in-house employee training and market-development training paid to a UK resident are taxable in India as fees for technical services under the India-UK treaty only if the services make available technical knowledge, experience, skill, know-how or processes, meaning the recipient is enabled to apply the technology itself. General training, even if specialised or useful, does not satisfy that treaty threshold unless it results in a transfer of technology. On the stated facts, the training was of a general nature and did not enable the assessee to apply any technical knowledge; the revenue also failed to establish that the treaty condition was met. Accordingly, the domestic charging provision could not be invoked, and the withholding demand was not sustainable. en-us Fri, 28 Jun 2013 00:00:00 +0530 Tue, 19 Aug 2025 17:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=242670 Fees for in-house employee training and market-development training paid to a UK resident are taxable in India as fees for technical services under the India-UK treaty only if the services make available technical knowledge, experience, skill, know-how or processes, meaning the recipient is enabled to apply the technology itself. General training, even if specialised or useful, does not satisfy that treaty threshold unless it results in a transfer of technology. On the stated facts, the training was of a general nature and did not enable the assessee to apply any technical knowledge; the revenue also failed to establish that the treaty condition was met. Accordingly, the domestic charging provision could not be invoked, and the withholding demand was not sustainable. Case-Laws Income Tax Fri, 28 Jun 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=242670