https://www.taxtmi.com/caselaws?id=404693 The Authority ruled that payments for "direct technical advice, support, and management including implementation" under IT services are characterized as Fee for Technical Services (FTS) under Article 13(4) of the India-UK DTAA. The payments under the Management Service Agreement (MSA) were not classified as "Royalty" under Article 13 of the India-UK DTAA. Additionally, the payments received were not considered business income due to the absence of a Permanent Establishment (PE) in India. Withholding tax under section 195 applies only to the specific component of "direct technical advice, support, and management including implementation" service under IT services at the applicable rate. en-us Thu, 04 Feb 2021 00:00:00 +0530 Wed, 07 Apr 2021 18:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=404693 The Authority ruled that payments for "direct technical advice, support, and management including implementation" under IT services are characterized as Fee for Technical Services (FTS) under Article 13(4) of the India-UK DTAA. The payments under the Management Service Agreement (MSA) were not classified as "Royalty" under Article 13 of the India-UK DTAA. Additionally, the payments received were not considered business income due to the absence of a Permanent Establishment (PE) in India. Withholding tax under section 195 applies only to the specific component of "direct technical advice, support, and management including implementation" service under IT services at the applicable rate. Case-Laws Income Tax Thu, 04 Feb 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=404693