https://www.taxtmi.com/caselaws?id=441317 Concurrent findings based on the agreement, invoices, bank records and remittance details showed that the payment was made to GIA USA, and the references to GIA Hong Kong were treated as clerical errors. The court held that the services did not transfer technical knowledge, experience, skill or know-how to the assessee, so the payment did not qualify as fees for technical services under the India-USA DTAA on a "make available" basis. In an appeal under section 260A, such findings could not be disturbed absent perversity, misreading of evidence or legal error, and no substantial question of law arose. en-us Mon, 31 Jul 2023 00:00:00 +0530 Thu, 28 May 2026 10:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=441317 Concurrent findings based on the agreement, invoices, bank records and remittance details showed that the payment was made to GIA USA, and the references to GIA Hong Kong were treated as clerical errors. The court held that the services did not transfer technical knowledge, experience, skill or know-how to the assessee, so the payment did not qualify as fees for technical services under the India-USA DTAA on a "make available" basis. In an appeal under section 260A, such findings could not be disturbed absent perversity, misreading of evidence or legal error, and no substantial question of law arose. Case-Laws Income Tax Mon, 31 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=441317