https://www.taxtmi.com/caselaws?id=764112 Administrative support service charges received from an Indian subsidiary were held not taxable as fees for technical services under Article 13(4) of the India-UK DTAA because the functions were group support and managerial in nature, with no transfer of technical knowledge, experience, skill, know-how or processes to the recipient. Reimbursements of expenses on a cost-to-cost basis were also held not taxable as fees for technical services, since no mark-up, profit element or separate technical service element was shown. The tribunal followed the earlier view in the assessee's own case and deleted the treaty-based additions. en-us Tue, 31 Dec 2024 00:00:00 +0530 Fri, 03 Jan 2025 08:45:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764112 Administrative support service charges received from an Indian subsidiary were held not taxable as fees for technical services under Article 13(4) of the India-UK DTAA because the functions were group support and managerial in nature, with no transfer of technical knowledge, experience, skill, know-how or processes to the recipient. Reimbursements of expenses on a cost-to-cost basis were also held not taxable as fees for technical services, since no mark-up, profit element or separate technical service element was shown. The tribunal followed the earlier view in the assessee's own case and deleted the treaty-based additions. Case-Laws Income Tax Tue, 31 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764112