https://www.taxtmi.com/caselaws?id=258118 Payments to a U.S. non-resident for calibration and testing of ultrasonic meters were not fee for technical services because the service provider only tested calibration and issued a correctness report, without making available technical knowledge, skill, or process to the recipient. On those facts, the Article 12(4) make-available test under the India-U.S.A. DTAA was not satisfied, so the remittance was not chargeable as FTS. Section 195 was therefore not attracted, and there was no liability under Sections 201(1) and 201(1A). en-us Fri, 14 Nov 2014 00:00:00 +0530 Tue, 31 Mar 2015 10:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=258118 Payments to a U.S. non-resident for calibration and testing of ultrasonic meters were not fee for technical services because the service provider only tested calibration and issued a correctness report, without making available technical knowledge, skill, or process to the recipient. On those facts, the Article 12(4) make-available test under the India-U.S.A. DTAA was not satisfied, so the remittance was not chargeable as FTS. Section 195 was therefore not attracted, and there was no liability under Sections 201(1) and 201(1A). Case-Laws Income Tax Fri, 14 Nov 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=258118