https://www.taxtmi.com/highlights?id=76012 Taxability of income in India - Taxability as Royalty or FTS - The tribunal systematically addressed the taxability of each type of service. It concluded that the services provided did not qualify as royalty or FTS under the India-Netherlands tax treaty because they did not make any technology, knowledge, experience, or skills "available" to the Indian group companies in such a manner that would enable them to perform these services independently in the future. The tribunal relied heavily on judicial precedents and the specific provisions of the India-Netherlands tax treaty, notably the "make available" clause. en-us Sat, 23 Mar 2024 08:25:14 +0530 Sat, 23 Mar 2024 08:25:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=76012 Taxability of income in India - Taxability as Royalty or FTS - The tribunal systematically addressed the taxability of each type of service. It concluded that the services provided did not qualify as royalty or FTS under the India-Netherlands tax treaty because they did not make any technology, knowledge, experience, or skills "available" to the Indian group companies in such a manner that would enable them to perform these services independently in the future. The tribunal relied heavily on judicial precedents and the specific provisions of the India-Netherlands tax treaty, notably the "make available" clause. Highlights Income Tax Sat, 23 Mar 2024 08:25:14 +0530 https://www.taxtmi.com/highlights?id=76012