https://www.taxtmi.com/caselaws?id=438414 Consideration for financial, technical, sales and legal support services was held not to constitute fees for technical services under Article 13(4)(c) of the India-UK DTAA because the services did not satisfy the make available test. The support functions were administrative and managerial in nature, and there was no transfer of technical knowledge, experience, skill, know-how or processes enabling the recipient to apply them independently in future. Repeated, continuing assistance requiring the recipient to return for the same support confirmed the absence of independent technical capability. The addition treating the receipts as fees for technical services was deleted. en-us Fri, 26 May 2023 00:00:00 +0530 Wed, 31 May 2023 09:44:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=438414 Consideration for financial, technical, sales and legal support services was held not to constitute fees for technical services under Article 13(4)(c) of the India-UK DTAA because the services did not satisfy the make available test. The support functions were administrative and managerial in nature, and there was no transfer of technical knowledge, experience, skill, know-how or processes enabling the recipient to apply them independently in future. Repeated, continuing assistance requiring the recipient to return for the same support confirmed the absence of independent technical capability. The addition treating the receipts as fees for technical services was deleted. Case-Laws Income Tax Fri, 26 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=438414