https://www.taxtmi.com/caselaws?id=450435 Bombay HC quashed AAR ruling requiring TDS withholding under section 195 on payments to non-resident group company for General Business Support Services under Cost Contribution Arrangement. Court held AAR erroneously classified managerial services as technical/consultancy services under Article 13 of India-UK DTAA. The services were purely managerial, not technical in nature, and did not "make available" technical knowledge as required by the treaty. AAR failed to properly interpret Article 13's scope and did not determine permanent establishment status under Article 5. en-us Fri, 01 Mar 2024 00:00:00 +0530 Wed, 01 Apr 2026 14:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450435 Bombay HC quashed AAR ruling requiring TDS withholding under section 195 on payments to non-resident group company for General Business Support Services under Cost Contribution Arrangement. Court held AAR erroneously classified managerial services as technical/consultancy services under Article 13 of India-UK DTAA. The services were purely managerial, not technical in nature, and did not "make available" technical knowledge as required by the treaty. AAR failed to properly interpret Article 13's scope and did not determine permanent establishment status under Article 5. Case-Laws Income Tax Fri, 01 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450435