https://www.taxtmi.com/caselaws?id=362138 Inspection, testing, analysis and certification receipts from services rendered largely outside India were not taxable as fees for technical services under Article 13(4)(c) of the India-United Kingdom DTAA because the services did not make available technical knowledge, experience, skill or know-how to the Indian recipients; mere performance of technical services was insufficient. The concealment penalty under section 271(1)(c) was also deleted because the assessee had made a bona fide, debatable treaty claim and the record did not show false particulars or concealment. The receipts were therefore held not chargeable to tax in India and the penalty was unsustainable. en-us Mon, 18 Jun 2018 00:00:00 +0530 Tue, 24 Jul 2018 17:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=362138 Inspection, testing, analysis and certification receipts from services rendered largely outside India were not taxable as fees for technical services under Article 13(4)(c) of the India-United Kingdom DTAA because the services did not make available technical knowledge, experience, skill or know-how to the Indian recipients; mere performance of technical services was insufficient. The concealment penalty under section 271(1)(c) was also deleted because the assessee had made a bona fide, debatable treaty claim and the record did not show false particulars or concealment. The receipts were therefore held not chargeable to tax in India and the penalty was unsustainable. Case-Laws Income Tax Mon, 18 Jun 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=362138