https://www.taxtmi.com/caselaws?id=298056 Management services under the India-Netherlands tax treaty were treated as outside fees for technical services because the core arrangement was managerial in nature, and the revenue failed to identify any separable technical or consultancy component. Even where some technical or consultancy features existed, the receipt was not taxable as fees for technical services because the treaty's make available condition was not satisfied: no technical knowledge, experience, skill, knowhow or process was shown to have been transmitted for independent future use by the recipient. The addition on fees for technical services was therefore unsustainable. en-us Tue, 30 Apr 2019 00:00:00 +0530 Fri, 08 Oct 2021 08:19:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=298056 Management services under the India-Netherlands tax treaty were treated as outside fees for technical services because the core arrangement was managerial in nature, and the revenue failed to identify any separable technical or consultancy component. Even where some technical or consultancy features existed, the receipt was not taxable as fees for technical services because the treaty's make available condition was not satisfied: no technical knowledge, experience, skill, knowhow or process was shown to have been transmitted for independent future use by the recipient. The addition on fees for technical services was therefore unsustainable. Case-Laws Income Tax Tue, 30 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=298056