https://www.taxtmi.com/caselaws?id=304491 A fixed place permanent establishment under Article 5(1) of the Indo-Sweden DTAA was not established because the assessee had no place of disposal in India from which it could conduct business, and the earlier tribunal view on identical facts was followed. The managerial services were not taxable as fee for technical services because they did not make available technical knowledge, skill or know-how to the recipient, nor enable independent future application. On both issues, the ruling remained in favour of the assessee and the revenue's challenge failed. en-us Mon, 27 Sep 2021 00:00:00 +0530 Wed, 28 Sep 2022 20:34:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=304491 A fixed place permanent establishment under Article 5(1) of the Indo-Sweden DTAA was not established because the assessee had no place of disposal in India from which it could conduct business, and the earlier tribunal view on identical facts was followed. The managerial services were not taxable as fee for technical services because they did not make available technical knowledge, skill or know-how to the recipient, nor enable independent future application. On both issues, the ruling remained in favour of the assessee and the revenue's challenge failed. Case-Laws Income Tax Mon, 27 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=304491