https://www.taxtmi.com/caselaws?id=432514 For treaty purposes, managerial, marketing consultancy and employee training services were not taxable as fees for technical services where they did not make available technical knowledge, experience, skill, know-how or processes for independent future use. The India-Sweden treaty MFN protocol allowed application of the narrower India-Portugal-style make available test, so the consultancy and training receipts were deleted. Claims described as reimbursement of expenses and recovery of expatriates' salary cost were not finally accepted as exempt; both lacked sufficient correlation with the underlying costs and were remanded to the Assessing Officer for fresh verification. The result was partial relief, with one receipt deleted and the other two matters restored for reconsideration. en-us Wed, 20 Jul 2022 00:00:00 +0530 Sat, 07 Jan 2023 08:48:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=432514 For treaty purposes, managerial, marketing consultancy and employee training services were not taxable as fees for technical services where they did not make available technical knowledge, experience, skill, know-how or processes for independent future use. The India-Sweden treaty MFN protocol allowed application of the narrower India-Portugal-style make available test, so the consultancy and training receipts were deleted. Claims described as reimbursement of expenses and recovery of expatriates' salary cost were not finally accepted as exempt; both lacked sufficient correlation with the underlying costs and were remanded to the Assessing Officer for fresh verification. The result was partial relief, with one receipt deleted and the other two matters restored for reconsideration. Case-Laws Income Tax Wed, 20 Jul 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432514