https://www.taxtmi.com/caselaws?id=307652 Management support services were not taxable as fees for technical services under the India-France tax treaty because the treaty protocol, including its most favoured nation clause, was treated as part of the treaty without separate notification. The clause imported the India-UK treaty's narrower fees for technical services scope, including the make available requirement, which the services did not meet. Material obtained by the CIT(A) through further inquiry powers for deciding an appeal did not constitute admission of additional evidence in breach of Rule 46A. Consequently, the additions were not sustained and the appellate relief remained intact. en-us Fri, 23 Sep 2022 00:00:00 +0530 Wed, 26 Apr 2023 21:53:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307652 Management support services were not taxable as fees for technical services under the India-France tax treaty because the treaty protocol, including its most favoured nation clause, was treated as part of the treaty without separate notification. The clause imported the India-UK treaty's narrower fees for technical services scope, including the make available requirement, which the services did not meet. Material obtained by the CIT(A) through further inquiry powers for deciding an appeal did not constitute admission of additional evidence in breach of Rule 46A. Consequently, the additions were not sustained and the appellate relief remained intact. Case-Laws Income Tax Fri, 23 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307652