https://www.taxtmi.com/caselaws?id=767075 ITAT Delhi held that fees received by UK entity for services under group service agreement and advisory services to Indian company do not constitute Fee for Technical Services under Article 13(4) of India-UK DTAA. Tribunal found that advisory services including identifying potential buyers, preparing management presentations, and transaction evaluation did not satisfy the "make available" clause requiring transfer of technical knowledge or skills. Following precedent from earlier assessment years, receipts were ruled non-taxable in India as they fell outside FTS definition under the treaty. en-us Fri, 07 Mar 2025 00:00:00 +0530 Mon, 10 Mar 2025 08:42:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767075 ITAT Delhi held that fees received by UK entity for services under group service agreement and advisory services to Indian company do not constitute Fee for Technical Services under Article 13(4) of India-UK DTAA. Tribunal found that advisory services including identifying potential buyers, preparing management presentations, and transaction evaluation did not satisfy the "make available" clause requiring transfer of technical knowledge or skills. Following precedent from earlier assessment years, receipts were ruled non-taxable in India as they fell outside FTS definition under the treaty. Case-Laws Income Tax Fri, 07 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767075