https://www.taxtmi.com/caselaws?id=443063 Business support service receipts under the India-Portugal DTAA were not taxable as fee for technical services under Article 12(4)(a) or Article 12(4)(b). The services were separate from the royalty-linked trademark and technology licence, were not ancillary or subsidiary to the enjoyment of any right or information for which royalty was paid, and did not involve making technical knowledge, skill, know-how or experience available for independent future use. The reimbursement of expenses on a cost-to-cost basis was not finally determined because the factual nature of the reimbursement was not fully verified, so the matter required fresh examination. en-us Wed, 13 Sep 2023 00:00:00 +0530 Fri, 15 Sep 2023 08:54:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=443063 Business support service receipts under the India-Portugal DTAA were not taxable as fee for technical services under Article 12(4)(a) or Article 12(4)(b). The services were separate from the royalty-linked trademark and technology licence, were not ancillary or subsidiary to the enjoyment of any right or information for which royalty was paid, and did not involve making technical knowledge, skill, know-how or experience available for independent future use. The reimbursement of expenses on a cost-to-cost basis was not finally determined because the factual nature of the reimbursement was not fully verified, so the matter required fresh examination. Case-Laws Income Tax Wed, 13 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=443063