https://www.taxtmi.com/caselaws?id=313981 Centralised intra-group administrative and day-to-day support services are described as falling outside fees for technical services or fees for included services where they do not make available technical knowledge, experience, skill, know-how or processes to the recipient under the India-US DTAA. Pure reimbursements of third-party expenses, supported by invoices and received without markup, are also treated as outside the tax net because no income element is embedded in the receipts. The commentary therefore distinguishes managerial or support functions from taxable technical services and separates cost recovery from income-bearing consideration. en-us Tue, 28 Mar 2023 00:00:00 +0530 Sat, 11 May 2024 08:33:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=313981 Centralised intra-group administrative and day-to-day support services are described as falling outside fees for technical services or fees for included services where they do not make available technical knowledge, experience, skill, know-how or processes to the recipient under the India-US DTAA. Pure reimbursements of third-party expenses, supported by invoices and received without markup, are also treated as outside the tax net because no income element is embedded in the receipts. The commentary therefore distinguishes managerial or support functions from taxable technical services and separates cost recovery from income-bearing consideration. Case-Laws Income Tax Tue, 28 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=313981