https://www.taxtmi.com/caselaws?id=418934 Routine business support services from Belgium were treated as not making available technical knowledge, experience, skill, know-how or processes to the Indian recipient, so the group management fees did not qualify as fees for technical services under the treaty framework. Applying the most-favoured nation clause, the restrictive make-available test under the India-Portugal treaty was considered relevant, and the treaty-based addition was deleted. Where tax was computed at the DTAA rate, surcharge and education cess were also held not separately leviable, so the computation had to be confined to the treaty rate without further levy. en-us Thu, 17 Feb 2022 00:00:00 +0530 Mon, 25 Aug 2025 14:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=418934 Routine business support services from Belgium were treated as not making available technical knowledge, experience, skill, know-how or processes to the Indian recipient, so the group management fees did not qualify as fees for technical services under the treaty framework. Applying the most-favoured nation clause, the restrictive make-available test under the India-Portugal treaty was considered relevant, and the treaty-based addition was deleted. Where tax was computed at the DTAA rate, surcharge and education cess were also held not separately leviable, so the computation had to be confined to the treaty rate without further levy. Case-Laws Income Tax Thu, 17 Feb 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=418934