https://www.taxtmi.com/caselaws?id=325780 Management service fees paid by an Indian subsidiary were treated as fees for technical services under the India-Sweden treaty only if the treaty's protocol and most favoured nation clause could import the later, more restrictive "make available" condition from the India-Portugal treaty. The protocol was read as part of the treaty framework, and the imported condition was applied to test taxability. Because the services involving management, marketing, HR, administration and coordination did not make available technical knowledge, skill, know-how or processes to the recipient, the fees were held not taxable in India and the addition was deleted. en-us Fri, 19 Feb 2016 00:00:00 +0530 Tue, 29 Mar 2016 10:46:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=325780 Management service fees paid by an Indian subsidiary were treated as fees for technical services under the India-Sweden treaty only if the treaty's protocol and most favoured nation clause could import the later, more restrictive "make available" condition from the India-Portugal treaty. The protocol was read as part of the treaty framework, and the imported condition was applied to test taxability. Because the services involving management, marketing, HR, administration and coordination did not make available technical knowledge, skill, know-how or processes to the recipient, the fees were held not taxable in India and the addition was deleted. Case-Laws Income Tax Fri, 19 Feb 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=325780