https://www.taxtmi.com/highlights?id=67441 Income deemed to accrue or arise in India - MOU to the India US DTAA elaborates on the concept of "make available" - Merely providing commercial information through a benchmarking study does not in any manner makes available any technical knowledge, experience, skill, know how or processes, nor consist of the development and transfer of a technical plan or technical design. Thus, the services of PTAI cannot be said to be FIS under covered Article 12. - AT en-us Mon, 02 Jan 2023 14:41:31 +0530 Mon, 02 Jan 2023 14:41:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=67441 Income deemed to accrue or arise in India - MOU to the India US DTAA elaborates on the concept of "make available" - Merely providing commercial information through a benchmarking study does not in any manner makes available any technical knowledge, experience, skill, know how or processes, nor consist of the development and transfer of a technical plan or technical design. Thus, the services of PTAI cannot be said to be FIS under covered Article 12. - AT Highlights Income Tax Mon, 02 Jan 2023 14:41:31 +0530 https://www.taxtmi.com/highlights?id=67441