https://www.taxtmi.com/caselaws?id=264289 Management service fees received from Indian group entities fall outside fees for technical services under the India-Sweden treaty where the treaty protocol's most favoured nation clause imports the narrower India-Portugal standard. That standard requires services to make available technical knowledge, skill, know-how or processes to the recipient. Managerial, commercial, marketing, administrative and support services do not satisfy that condition merely because they are rendered. Consequently, the fees are not taxable in India as fees for technical services under the treaty, and the related addition is deleted. en-us Fri, 22 May 2015 00:00:00 +0530 Tue, 22 Sep 2015 06:54:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=264289 Management service fees received from Indian group entities fall outside fees for technical services under the India-Sweden treaty where the treaty protocol's most favoured nation clause imports the narrower India-Portugal standard. That standard requires services to make available technical knowledge, skill, know-how or processes to the recipient. Managerial, commercial, marketing, administrative and support services do not satisfy that condition merely because they are rendered. Consequently, the fees are not taxable in India as fees for technical services under the treaty, and the related addition is deleted. Case-Laws Income Tax Fri, 22 May 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=264289