https://www.taxtmi.com/caselaws?id=427656 Management support fees were held not taxable as fees for technical services, following the assessee's earlier-year precedent and the applicable treaty position. For human resources services and leadership seminar or conference receipts, Article 12(4)(b) of the India-Portuguese treaty was applied on the basis that technical or consultancy services are taxable as fees for included services only if they make available technical knowledge, experience, skill, know-how or processes, or transfer a technical plan or design. The leadership training receipt was held not chargeable to tax, while the human resources and overlapping receipts required fresh factual examination and were remanded to the Assessing Officer. en-us Mon, 12 Sep 2022 00:00:00 +0530 Wed, 14 Sep 2022 09:23:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=427656 Management support fees were held not taxable as fees for technical services, following the assessee's earlier-year precedent and the applicable treaty position. For human resources services and leadership seminar or conference receipts, Article 12(4)(b) of the India-Portuguese treaty was applied on the basis that technical or consultancy services are taxable as fees for included services only if they make available technical knowledge, experience, skill, know-how or processes, or transfer a technical plan or design. The leadership training receipt was held not chargeable to tax, while the human resources and overlapping receipts required fresh factual examination and were remanded to the Assessing Officer. Case-Laws Income Tax Mon, 12 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=427656