https://www.taxtmi.com/caselaws?id=766172 Income from diamond certification services was treated by the Gujarat HC as protected under the India-USA DTAA on factual findings from the customer service agreement, bank invoice and remittance advice; it held that mere rendering of services is not enough to constitute fees for technical services unless the recipient can use the technical knowledge or skill made available. In the Supreme Court, the matter was disposed of because the tax effect fell below the threshold in the CBIC circular dated 22 August 2019, without any substantive adjudication on the merits. en-us Fri, 14 Feb 2025 00:00:00 +0530 Wed, 19 Feb 2025 08:42:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766172 Income from diamond certification services was treated by the Gujarat HC as protected under the India-USA DTAA on factual findings from the customer service agreement, bank invoice and remittance advice; it held that mere rendering of services is not enough to constitute fees for technical services unless the recipient can use the technical knowledge or skill made available. In the Supreme Court, the matter was disposed of because the tax effect fell below the threshold in the CBIC circular dated 22 August 2019, without any substantive adjudication on the merits. Case-Laws Income Tax Fri, 14 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766172