https://www.taxtmi.com/caselaws?id=456692 Consultancy services limited to market survey, business prospect assessment, manpower strategy, cash flow estimation and report preparation were held not to satisfy the India-UK treaty "make available" test. The services did not impart technical knowledge, skill or experience for independent use, nor did they involve transfer of a technical plan or design. Accordingly, the payment did not constitute fees for technical services under Article 13, and the amount was instead referable to the business profits article, which would require a permanent establishment in India. No tax was deductible at source on the payment, and the assessee could not be treated as in default. en-us Wed, 29 Jul 2015 00:00:00 +0530 Fri, 09 Aug 2024 00:18:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456692 Consultancy services limited to market survey, business prospect assessment, manpower strategy, cash flow estimation and report preparation were held not to satisfy the India-UK treaty "make available" test. The services did not impart technical knowledge, skill or experience for independent use, nor did they involve transfer of a technical plan or design. Accordingly, the payment did not constitute fees for technical services under Article 13, and the amount was instead referable to the business profits article, which would require a permanent establishment in India. No tax was deductible at source on the payment, and the assessee could not be treated as in default. Case-Laws Income Tax Wed, 29 Jul 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456692