https://www.taxtmi.com/caselaws?id=279851 Treaty protection under the India-Sweden protocol and the Most Favoured Nation clause can exclude management service and training receipts from Indian tax as fees for technical services or royalty, including where the services do not satisfy the make available condition. The same receipts should not be recharacterised as dividends when they are consideration for services rather than a distribution of profits. Where receipt ownership is disputed, taxability depends on verification of the correct recipient before any assessment is made in the assessee's hands. en-us Wed, 20 Dec 2017 00:00:00 +0530 Tue, 09 Apr 2019 05:48:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=279851 Treaty protection under the India-Sweden protocol and the Most Favoured Nation clause can exclude management service and training receipts from Indian tax as fees for technical services or royalty, including where the services do not satisfy the make available condition. The same receipts should not be recharacterised as dividends when they are consideration for services rather than a distribution of profits. Where receipt ownership is disputed, taxability depends on verification of the correct recipient before any assessment is made in the assessee's hands. Case-Laws Income Tax Wed, 20 Dec 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=279851