https://www.taxtmi.com/caselaws?id=459011 Repair and maintenance services for aircraft equipment were not taxable as fee for technical services under Article 12 of the India-USA DTAA because the recipient did not acquire the ability to perform similar work independently, and no technical knowledge, skill, know-how, process or experience was made available. Corporate allocation charges recovered on a reimbursement basis were also not taxable as fee for technical services because they represented actual expenditure without profit element and did not involve transfer of any independent technical capability. On both disputed service-receipt heads, the additions were deleted in favour of the assessee. en-us Thu, 22 Aug 2024 00:00:00 +0530 Tue, 26 Nov 2024 08:50:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459011 Repair and maintenance services for aircraft equipment were not taxable as fee for technical services under Article 12 of the India-USA DTAA because the recipient did not acquire the ability to perform similar work independently, and no technical knowledge, skill, know-how, process or experience was made available. Corporate allocation charges recovered on a reimbursement basis were also not taxable as fee for technical services because they represented actual expenditure without profit element and did not involve transfer of any independent technical capability. On both disputed service-receipt heads, the additions were deleted in favour of the assessee. Case-Laws Income Tax Thu, 22 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459011