https://www.taxtmi.com/caselaws?id=297770 Receipts from services rendered outside India were treated as fees for technical services under Article 13(4)(c) of the India-UK DTAA because the services made available technology to the recipient, satisfying the make available test. Article 13(6) was held inapplicable because the income did not arise through, or have effective connection with, a permanent establishment in India. The analysis also noted taxability under section 9(1)(vii)(b) of the Income-tax Act, 1961. The alternative claim for assessment under Article 7 on a permanent establishment basis was rejected. en-us Tue, 08 May 2018 00:00:00 +0530 Wed, 22 Sep 2021 06:16:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=297770 Receipts from services rendered outside India were treated as fees for technical services under Article 13(4)(c) of the India-UK DTAA because the services made available technology to the recipient, satisfying the make available test. Article 13(6) was held inapplicable because the income did not arise through, or have effective connection with, a permanent establishment in India. The analysis also noted taxability under section 9(1)(vii)(b) of the Income-tax Act, 1961. The alternative claim for assessment under Article 7 on a permanent establishment basis was rejected. Case-Laws Income Tax Tue, 08 May 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=297770