https://www.taxtmi.com/caselaws?id=755067 The Delhi HC ruled that IMG UK's services to BCCI for IPL organization did not qualify as Fee for Technical Services (FTS) under Article 13 of the India-UK DTAA, as the "make available" test was not satisfied. The court held that while IMG provided technical expertise and consultancy services, BCCI did not absorb or internalize IMG's specialized knowledge in sporting league creation. The court also found that services for IPL matches held in South Africa and UAE fell under Section 9(1)(vii) exception, being utilized outside India for earning income from foreign sources. The Tribunal's decision was partially overturned regarding FTS classification. en-us Wed, 03 Jul 2024 00:00:00 +0530 Thu, 29 Aug 2024 11:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755067 The Delhi HC ruled that IMG UK's services to BCCI for IPL organization did not qualify as Fee for Technical Services (FTS) under Article 13 of the India-UK DTAA, as the "make available" test was not satisfied. The court held that while IMG provided technical expertise and consultancy services, BCCI did not absorb or internalize IMG's specialized knowledge in sporting league creation. The court also found that services for IPL matches held in South Africa and UAE fell under Section 9(1)(vii) exception, being utilized outside India for earning income from foreign sources. The Tribunal's decision was partially overturned regarding FTS classification. Case-Laws Income Tax Wed, 03 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755067