https://www.taxtmi.com/caselaws?id=307653 Management support receipts for administration, planning, marketing, logistics and related business functions were treated as managerial in substance. Under the India-Belgium treaty protocol and the India-UK treaty definition, fee for technical services covered only technical or consultancy services, and consultancy services required that technical knowledge, experience, skill, know-how or processes be made available so the recipient could apply them independently. No material showed that this make available condition was satisfied, and the attribution of part of the receipts to consultancy services was unsupported. The receipt was therefore not taxable as fee for technical services, and the addition was deleted. en-us Wed, 28 Dec 2022 00:00:00 +0530 Mon, 18 Sep 2023 11:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307653 Management support receipts for administration, planning, marketing, logistics and related business functions were treated as managerial in substance. Under the India-Belgium treaty protocol and the India-UK treaty definition, fee for technical services covered only technical or consultancy services, and consultancy services required that technical knowledge, experience, skill, know-how or processes be made available so the recipient could apply them independently. No material showed that this make available condition was satisfied, and the attribution of part of the receipts to consultancy services was unsupported. The receipt was therefore not taxable as fee for technical services, and the addition was deleted. Case-Laws Income Tax Wed, 28 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307653