https://www.taxtmi.com/caselaws?id=759262 Cross-border IT support and related services to group entities are analysed under the India-USA DTAA and section 9(1)(vii) to test whether the services make available technical knowledge, skill, know-how or processes. The note states that centralized support, maintenance, helpdesk, data management, security, network and server functions did not transfer enduring technical capability to the recipient, so the receipts were not taxable in India as fees for included services or fees for technical services. It also notes that a mismatch between Form 26AS and Form 15CA calls for verification of the remittance figures against records available with the tax authority. en-us Fri, 26 Jul 2024 00:00:00 +0530 Mon, 05 Jan 2026 11:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759262 Cross-border IT support and related services to group entities are analysed under the India-USA DTAA and section 9(1)(vii) to test whether the services make available technical knowledge, skill, know-how or processes. The note states that centralized support, maintenance, helpdesk, data management, security, network and server functions did not transfer enduring technical capability to the recipient, so the receipts were not taxable in India as fees for included services or fees for technical services. It also notes that a mismatch between Form 26AS and Form 15CA calls for verification of the remittance figures against records available with the tax authority. Case-Laws Income Tax Fri, 26 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759262