https://www.taxtmi.com/caselaws?id=309416 Management support reimbursements under the India-US DTAA were not taxable as fees for technical services or fees for included services because the treaty required the services to make available technical knowledge, skill, know-how or processes to the recipient for independent future use. On the facts, the arrangement involved functional support, but it did not satisfy the make available condition, so the consideration fell outside Article 12. en-us Wed, 30 Oct 2019 00:00:00 +0530 Fri, 01 Sep 2023 22:30:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=309416 Management support reimbursements under the India-US DTAA were not taxable as fees for technical services or fees for included services because the treaty required the services to make available technical knowledge, skill, know-how or processes to the recipient for independent future use. On the facts, the arrangement involved functional support, but it did not satisfy the make available condition, so the consideration fell outside Article 12. Case-Laws Income Tax Wed, 30 Oct 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=309416