https://www.taxtmi.com/caselaws?id=431764 Specialised consulting, engineering and project support services were analysed under the India-UK tax treaty and found not to constitute fees for technical services because they did not make available technical knowledge, experience, skill, know-how or processes to the recipient. As a result, the receipts were treated as business profits and, absent a permanent establishment in India, were not taxable in India. On the same treaty basis, management fees and common cost recharges were also rejected as royalty or fees for technical services because the underlying arrangement did not satisfy the make-available test. The additions on these receipts were deleted. en-us Mon, 19 Dec 2022 00:00:00 +0530 Wed, 21 Dec 2022 09:18:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=431764 Specialised consulting, engineering and project support services were analysed under the India-UK tax treaty and found not to constitute fees for technical services because they did not make available technical knowledge, experience, skill, know-how or processes to the recipient. As a result, the receipts were treated as business profits and, absent a permanent establishment in India, were not taxable in India. On the same treaty basis, management fees and common cost recharges were also rejected as royalty or fees for technical services because the underlying arrangement did not satisfy the make-available test. The additions on these receipts were deleted. Case-Laws Income Tax Mon, 19 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=431764