https://www.taxtmi.com/caselaws?id=249729 Payments for BSP link services were not taxable in India as fees for included or technical services under Article 13 of the India-France DTAA because the services did not satisfy the "make available" standard. Although the arrangement covered development, testing, implementation and training, it did not transfer technical knowledge, experience, skill, know-how or processes enabling the recipient to apply the technology independently. On that basis, the sum was not chargeable to tax in India on this footing, and no deduction of tax at source under section 195 was required. en-us Wed, 11 Jun 2014 00:00:00 +0530 Tue, 22 Jul 2014 17:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=249729 Payments for BSP link services were not taxable in India as fees for included or technical services under Article 13 of the India-France DTAA because the services did not satisfy the "make available" standard. Although the arrangement covered development, testing, implementation and training, it did not transfer technical knowledge, experience, skill, know-how or processes enabling the recipient to apply the technology independently. On that basis, the sum was not chargeable to tax in India on this footing, and no deduction of tax at source under section 195 was required. Case-Laws Income Tax Wed, 11 Jun 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=249729