https://www.taxtmi.com/caselaws?id=271000 Supply management service fees paid to a UK resident were not fees for technical services or royalty under Article 13 of the India-UK treaty because the services involved managerial and sourcing support only, with no transfer of technical knowledge, know-how, process, or intellectual property, and the "make available" test was not met. As no permanent establishment existed in India, the receipts were not taxable in India under the treaty. Since the underlying sum was not chargeable to tax in India, the Indian payer had no obligation to deduct tax at source under section 195 of the Income-tax Act, 1961. en-us Tue, 12 Jan 2016 00:00:00 +0530 Tue, 03 May 2016 11:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=271000 Supply management service fees paid to a UK resident were not fees for technical services or royalty under Article 13 of the India-UK treaty because the services involved managerial and sourcing support only, with no transfer of technical knowledge, know-how, process, or intellectual property, and the "make available" test was not met. As no permanent establishment existed in India, the receipts were not taxable in India under the treaty. Since the underlying sum was not chargeable to tax in India, the Indian payer had no obligation to deduct tax at source under section 195 of the Income-tax Act, 1961. Case-Laws Income Tax Tue, 12 Jan 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=271000