https://www.taxtmi.com/caselaws?id=767479 Reimbursement of software licence costs for group use was treated as an administrative or commercial arrangement, not as the rendering of managerial, technical or consultancy services. Because no technical knowledge, skill, experience or know-how was made available to the Indian entities, the GIS Charges were held not to be Fees for Technical Services under the India-UK DTAA, and the related tax addition was deleted. The fee under section 234F was to be recomputed in line with the applicable limit for the relevant year, and the matter was remitted for that limited purpose. en-us Mon, 17 Feb 2025 00:00:00 +0530 Wed, 19 Mar 2025 06:45:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767479 Reimbursement of software licence costs for group use was treated as an administrative or commercial arrangement, not as the rendering of managerial, technical or consultancy services. Because no technical knowledge, skill, experience or know-how was made available to the Indian entities, the GIS Charges were held not to be Fees for Technical Services under the India-UK DTAA, and the related tax addition was deleted. The fee under section 234F was to be recomputed in line with the applicable limit for the relevant year, and the matter was remitted for that limited purpose. Case-Laws Income Tax Mon, 17 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767479