https://www.taxtmi.com/caselaws?id=393931 A payment is taxable as fees for technical services only where the underlying arrangement, on proper factual examination, shows managerial, technical or consultancy character and, where the treaty requires it, the relevant make available element. On that basis, corporate guarantee fee was held not taxable as FTS, while management fee and reimbursement of social security contribution expenses were remanded for fresh verification of the agreements and supporting evidence. Education cess and secondary and higher education cess could not be levied over a DTAA gross-rate tax, and the cess additions were deleted. TDS credit was also sent back for verification and allowance in accordance with law. en-us Fri, 20 Mar 2020 00:00:00 +0530 Wed, 24 Jun 2020 14:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=393931 A payment is taxable as fees for technical services only where the underlying arrangement, on proper factual examination, shows managerial, technical or consultancy character and, where the treaty requires it, the relevant make available element. On that basis, corporate guarantee fee was held not taxable as FTS, while management fee and reimbursement of social security contribution expenses were remanded for fresh verification of the agreements and supporting evidence. Education cess and secondary and higher education cess could not be levied over a DTAA gross-rate tax, and the cess additions were deleted. TDS credit was also sent back for verification and allowance in accordance with law. Case-Laws Income Tax Fri, 20 Mar 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=393931