https://www.taxtmi.com/caselaws?id=439811 ITAT Delhi held that intragroup receipts for management, finance, legal, compliance, internal audit, planning and marketing support on a cost-recharge basis were advisory or assisting services, not technical or consultancy services for Article 13(4) of the India-UK DTAA. Even if some elements were technical in nature, the decisive make available test was not satisfied because the services did not transfer technical knowledge, experience, skill, know-how or processes enabling the Indian entity to perform the functions independently in future. The receipts therefore did not constitute fees for technical services and were not taxable in India. en-us Fri, 30 Jun 2023 00:00:00 +0530 Mon, 03 Jul 2023 08:38:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=439811 ITAT Delhi held that intragroup receipts for management, finance, legal, compliance, internal audit, planning and marketing support on a cost-recharge basis were advisory or assisting services, not technical or consultancy services for Article 13(4) of the India-UK DTAA. Even if some elements were technical in nature, the decisive make available test was not satisfied because the services did not transfer technical knowledge, experience, skill, know-how or processes enabling the Indian entity to perform the functions independently in future. The receipts therefore did not constitute fees for technical services and were not taxable in India. Case-Laws Income Tax Fri, 30 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=439811