https://www.taxtmi.com/caselaws?id=412568 Balance receipts not attributable to a permanent establishment were analysed under Article 13 of the India-UK DTAA to determine whether they constituted fees for technical services and satisfied the make available requirement. As the material facts were identical to the assessee's earlier years and no distinguishing feature was shown, the Tribunal followed its coordinate bench ruling in those years and applied the same treaty characterisation. The receipts were treated as taxable fees for technical services under the DTAA, and the assessee's challenge failed. en-us Wed, 08 Sep 2021 00:00:00 +0530 Tue, 21 Sep 2021 17:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=412568 Balance receipts not attributable to a permanent establishment were analysed under Article 13 of the India-UK DTAA to determine whether they constituted fees for technical services and satisfied the make available requirement. As the material facts were identical to the assessee's earlier years and no distinguishing feature was shown, the Tribunal followed its coordinate bench ruling in those years and applied the same treaty characterisation. The receipts were treated as taxable fees for technical services under the DTAA, and the assessee's challenge failed. Case-Laws Income Tax Wed, 08 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=412568