https://www.taxtmi.com/caselaws?id=334047 The tribunal dismissed the appeal of the assessee and allowed the appeal of the revenue, holding that the balance receipt of Rs. 237,750,181 was chargeable to tax as Fees for Technical Services (FTS) under Article 13 of the India-UK Double Taxation Avoidance Agreement and Section 9(i)(vii) of the Income Tax Act. The tribunal found that the receipts satisfied the "make available" test and did not fall under the exclusion clause of Section 9(i)(vii)(b). en-us Tue, 04 Oct 2016 00:00:00 +0530 Mon, 21 Nov 2016 10:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=334047 The tribunal dismissed the appeal of the assessee and allowed the appeal of the revenue, holding that the balance receipt of Rs. 237,750,181 was chargeable to tax as Fees for Technical Services (FTS) under Article 13 of the India-UK Double Taxation Avoidance Agreement and Section 9(i)(vii) of the Income Tax Act. The tribunal found that the receipts satisfied the "make available" test and did not fall under the exclusion clause of Section 9(i)(vii)(b). Case-Laws Income Tax Tue, 04 Oct 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=334047