https://www.taxtmi.com/caselaws?id=755067 Under the India-UK DTAA, receipts under a composite contract could be separately characterised, so income attributable to services through a Service PE could be treated as business profits while other receipts remained examinable under Article 13. The Court also applied the Article 13(4)(c) "make available" test and held that advisory and technical assistance to BCCI did not transfer technical knowledge or skill for independent future use; the receipts were therefore not fees for technical services. For years when the IPL was held in South Africa and the UAE, Section 9(1)(vii)(b) was held inapplicable because the services were utilised outside India for foreign-source income. en-us Wed, 03 Jul 2024 00:00:00 +0530 Thu, 04 Jul 2024 14:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755067 Under the India-UK DTAA, receipts under a composite contract could be separately characterised, so income attributable to services through a Service PE could be treated as business profits while other receipts remained examinable under Article 13. The Court also applied the Article 13(4)(c) "make available" test and held that advisory and technical assistance to BCCI did not transfer technical knowledge or skill for independent future use; the receipts were therefore not fees for technical services. For years when the IPL was held in South Africa and the UAE, Section 9(1)(vii)(b) was held inapplicable because the services were utilised outside India for foreign-source income. Case-Laws Income Tax Wed, 03 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755067