https://www.taxtmi.com/caselaws?id=757720 Routine IT support services under a DTAA were analysed against the fees for technical services and fees for included services tests, and were found not taxable where they did not transfer technology, technical knowledge, skill, know-how or processes to the recipient. Assistance or training alone was insufficient because the recipient was not enabled to apply the technology independently. The document further states that the make available condition was not satisfied and that cost-to-cost allocations without markup or profit element retained the character of reimbursement rather than income chargeable to tax. en-us Tue, 23 Jul 2024 00:00:00 +0530 Sat, 31 Aug 2024 07:53:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757720 Routine IT support services under a DTAA were analysed against the fees for technical services and fees for included services tests, and were found not taxable where they did not transfer technology, technical knowledge, skill, know-how or processes to the recipient. Assistance or training alone was insufficient because the recipient was not enabled to apply the technology independently. The document further states that the make available condition was not satisfied and that cost-to-cost allocations without markup or profit element retained the character of reimbursement rather than income chargeable to tax. Case-Laws Income Tax Tue, 23 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757720