https://www.taxtmi.com/caselaws?id=456692 ITAT Mumbai dismissed Revenue's appeals regarding TDS u/s 195 on payments to foreign entity. The Tribunal held that market survey services provided by UK company for determining business prospects did not constitute technical services under Article 13(4)(c) of Indo-UK DTAA. Services must transfer technical knowledge that recipient can use independently without future recourse to service provider. Since survey services did not impart technical knowledge or involve development/transfer of technical design, payment of GBP 88,950 did not qualify as Fees for Technical Services under treaty provisions. 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 ITAT Mumbai dismissed Revenue's appeals regarding TDS u/s 195 on payments to foreign entity. The Tribunal held that market survey services provided by UK company for determining business prospects did not constitute technical services under Article 13(4)(c) of Indo-UK DTAA. Services must transfer technical knowledge that recipient can use independently without future recourse to service provider. Since survey services did not impart technical knowledge or involve development/transfer of technical design, payment of GBP 88,950 did not qualify as Fees for Technical Services under treaty provisions. Case-Laws Income Tax Wed, 29 Jul 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456692