https://www.taxtmi.com/caselaws?id=432152 Payment for IT support services to a UK group company was not fees for technical services under Article 13(4)(c) of the India-UK DTAA because the services did not make available technical knowledge, experience, skill, know-how or processes to the assessee. Mere use of sophisticated support, incidental benefit, or business convenience was insufficient, and the record showed no transfer of technology enabling the assessee to perform the same services independently. The payment was therefore not taxable as FTS, and disallowance under section 40(a)(i) was unsustainable. en-us Thu, 22 Dec 2022 00:00:00 +0530 Thu, 29 Dec 2022 09:13:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=432152 Payment for IT support services to a UK group company was not fees for technical services under Article 13(4)(c) of the India-UK DTAA because the services did not make available technical knowledge, experience, skill, know-how or processes to the assessee. Mere use of sophisticated support, incidental benefit, or business convenience was insufficient, and the record showed no transfer of technology enabling the assessee to perform the same services independently. The payment was therefore not taxable as FTS, and disallowance under section 40(a)(i) was unsustainable. Case-Laws Income Tax Thu, 22 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432152