https://www.taxtmi.com/caselaws?id=456581 Under Article 13 of the India-UK DTAA and section 9, supply planning receipts were held not to be royalty or fees for technical services because the activities were limited to commercial information exchange, extranet communication, and account coordination, without making available technical knowledge or using protected commercial rights. Grading receipts for diamond examination, testing, and certification were also held not to be royalty, as the service provider did not transfer any copyright, trademark, process, or know-how to the customer. Receipts under the DTC Accredited Business Programme were likewise held not taxable as royalty or fees for technical services, since no intellectual property right or make-available element was established. en-us Fri, 15 Dec 2023 00:00:00 +0530 Thu, 01 Aug 2024 20:47:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456581 Under Article 13 of the India-UK DTAA and section 9, supply planning receipts were held not to be royalty or fees for technical services because the activities were limited to commercial information exchange, extranet communication, and account coordination, without making available technical knowledge or using protected commercial rights. Grading receipts for diamond examination, testing, and certification were also held not to be royalty, as the service provider did not transfer any copyright, trademark, process, or know-how to the customer. Receipts under the DTC Accredited Business Programme were likewise held not taxable as royalty or fees for technical services, since no intellectual property right or make-available element was established. Case-Laws Income Tax Fri, 15 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456581