https://www.taxtmi.com/caselaws?id=311212 Amounts recovered for a standard group-wide software facility, together with marketing and training-related reimbursements, were not fees for technical services because no technical knowledge, skill, know-how, or technical plan was made available under article 13(4)(c) of the Indo-UK DTAA. The receipts were also not supportable as royalty on the record. Where the earlier remand was confined to the treaty test for fees for technical services, the Assessing Officer could not enlarge the enquiry by recharacterising the same receipts as royalty; that departure from the remand scope rendered the assessment unsustainable and the additions were deleted. en-us Wed, 25 Jan 2023 00:00:00 +0530 Thu, 14 Dec 2023 08:28:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311212 Amounts recovered for a standard group-wide software facility, together with marketing and training-related reimbursements, were not fees for technical services because no technical knowledge, skill, know-how, or technical plan was made available under article 13(4)(c) of the Indo-UK DTAA. The receipts were also not supportable as royalty on the record. Where the earlier remand was confined to the treaty test for fees for technical services, the Assessing Officer could not enlarge the enquiry by recharacterising the same receipts as royalty; that departure from the remand scope rendered the assessment unsustainable and the additions were deleted. Case-Laws Income Tax Wed, 25 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311212