https://www.taxtmi.com/caselaws?id=378161 Project-specific consulting engineering drawings, designs and plans were examined under Article 13(4)(c) of the India-UK treaty, which requires that technical knowledge, experience, skill, know-how or processes be made available to the recipient. Because the materials were not shown to equip the recipient to use the expertise independently in future projects, the receipts did not qualify as fees for technical services and were treated as business profits not taxable in India absent a permanent establishment. The related common cost recharge, lacking an independent tax basis, was also not taxable in India, and the additions were deleted. en-us Fri, 15 Feb 2019 00:00:00 +0530 Tue, 09 Apr 2019 10:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=378161 Project-specific consulting engineering drawings, designs and plans were examined under Article 13(4)(c) of the India-UK treaty, which requires that technical knowledge, experience, skill, know-how or processes be made available to the recipient. Because the materials were not shown to equip the recipient to use the expertise independently in future projects, the receipts did not qualify as fees for technical services and were treated as business profits not taxable in India absent a permanent establishment. The related common cost recharge, lacking an independent tax basis, was also not taxable in India, and the additions were deleted. Case-Laws Income Tax Fri, 15 Feb 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=378161