https://www.taxtmi.com/caselaws?id=439892 Receipts for services to an Indian subsidiary were not taxable as fees for technical services under the treaty because the services were mainly routine management support and the Revenue did not show that technical knowledge, experience, skill, knowhow or processes were made available to enable independent use by the recipient. Applying the Most Favoured Nation clause to Article 13(4) of the India-UK DTAA through the India-France DTAA protocol, the tribunal held that the make available condition was not satisfied, so the service receipts were excluded. Reimbursement of expenses was also not separately taxable as fees for technical services on the same contractual and treaty footing, so no addition survived. en-us Fri, 16 Jun 2023 00:00:00 +0530 Wed, 31 Jan 2024 13:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=439892 Receipts for services to an Indian subsidiary were not taxable as fees for technical services under the treaty because the services were mainly routine management support and the Revenue did not show that technical knowledge, experience, skill, knowhow or processes were made available to enable independent use by the recipient. Applying the Most Favoured Nation clause to Article 13(4) of the India-UK DTAA through the India-France DTAA protocol, the tribunal held that the make available condition was not satisfied, so the service receipts were excluded. Reimbursement of expenses was also not separately taxable as fees for technical services on the same contractual and treaty footing, so no addition survived. Case-Laws Income Tax Fri, 16 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=439892