https://www.taxtmi.com/caselaws?id=767075 Receipts from intra-group and advisory services were treated as outside fees for technical services under Article 13 of the India-UK DTAA because the services were confined to managerial, compliance, finance, planning, marketing and transaction-support functions. They did not transfer technical knowledge, skill, know-how or processes to the recipient, so the make available under Article 13(4)(c) was not satisfied. As a result, the amounts were not taxable in India as fees for technical services and the addition was deleted. en-us Fri, 07 Mar 2025 00:00:00 +0530 Mon, 10 Mar 2025 08:42:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767075 Receipts from intra-group and advisory services were treated as outside fees for technical services under Article 13 of the India-UK DTAA because the services were confined to managerial, compliance, finance, planning, marketing and transaction-support functions. They did not transfer technical knowledge, skill, know-how or processes to the recipient, so the make available under Article 13(4)(c) was not satisfied. As a result, the amounts were not taxable in India as fees for technical services and the addition was deleted. Case-Laws Income Tax Fri, 07 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767075