https://www.taxtmi.com/caselaws?id=758877 Managerial services rendered to Indian branch offices and subsidiaries were not fees for technical services under Article 13(4)(a) of the India-UK DTAA merely because they shared a commercial objective with a licence arrangement; the treaty tests for ancillary and subsidiary character were not satisfied, and the make available requirement was not attracted. The Revenue's challenge on taxability therefore failed. The claim for short grant of TDS credit depended on verification of supporting records and pending rectification proceedings, so the matter was remitted to the Assessing Officer for examination and consequential credit, if due. en-us Fri, 30 Aug 2024 00:00:00 +0530 Fri, 20 Sep 2024 08:31:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=758877 Managerial services rendered to Indian branch offices and subsidiaries were not fees for technical services under Article 13(4)(a) of the India-UK DTAA merely because they shared a commercial objective with a licence arrangement; the treaty tests for ancillary and subsidiary character were not satisfied, and the make available requirement was not attracted. The Revenue's challenge on taxability therefore failed. The claim for short grant of TDS credit depended on verification of supporting records and pending rectification proceedings, so the matter was remitted to the Assessing Officer for examination and consequential credit, if due. Case-Laws Income Tax Fri, 30 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=758877