https://www.taxtmi.com/caselaws?id=432295 The Tribunal held that the receipts from the provision of information technology and administrative services were not Fees for Technical Services under the India-USA Double Taxation Avoidance Agreement. The services provided did not make technical knowledge available to the Indian affiliate independently, as required by the "make available" clause. The Tribunal directed the Assessing Officer to delete the addition made on this account, allowing the appeals of the assessee. en-us Fri, 30 Dec 2022 00:00:00 +0530 Mon, 02 Jan 2023 08:38:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=432295 The Tribunal held that the receipts from the provision of information technology and administrative services were not Fees for Technical Services under the India-USA Double Taxation Avoidance Agreement. The services provided did not make technical knowledge available to the Indian affiliate independently, as required by the "make available" clause. The Tribunal directed the Assessing Officer to delete the addition made on this account, allowing the appeals of the assessee. Case-Laws Income Tax Fri, 30 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432295