https://www.taxtmi.com/highlights?id=70055 Addition on account of services rendered by the assessee to its AE in India - whether FTS under the provisions of Article 13(4)(c) of the India-UK DTAA? - the assistance, support or advice provided by the assessee to BTPL shall not per se be considered to make technology available since the assessee did not make available any technical knowledge, experience or skill to BTPL by way of rendering the above support services to BTPL. Article 13(4) of the India–UK DTAA does not apply to the assessee’s case and hence the consideration could not be included in FTS. - AT en-us Wed, 31 May 2023 10:34:38 +0530 Wed, 31 May 2023 10:34:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=70055 Addition on account of services rendered by the assessee to its AE in India - whether FTS under the provisions of Article 13(4)(c) of the India-UK DTAA? - the assistance, support or advice provided by the assessee to BTPL shall not per se be considered to make technology available since the assessee did not make available any technical knowledge, experience or skill to BTPL by way of rendering the above support services to BTPL. Article 13(4) of the India–UK DTAA does not apply to the assessee’s case and hence the consideration could not be included in FTS. - AT Highlights Income Tax Wed, 31 May 2023 10:34:38 +0530 https://www.taxtmi.com/highlights?id=70055