https://www.taxtmi.com/caselaws?id=461233 Receipts under a Cost Contribution Agreement for general business support services were held not to constitute fees for technical services under the Income-tax Act, 1961 or Article 13 of the India-UK DTAA. The Tribunal applied the jurisdictional High Court's ruling that the same services were managerial in nature and did not make available technical knowledge, skill, experience, know-how or processes to the Indian entity. Mere use of expertise in rendering management, marketing, legal, financial, taxation, HR and procurement support was insufficient to characterise the receipts as technical fees. The addition was therefore deleted. en-us Tue, 10 Sep 2024 00:00:00 +0530 Sat, 22 Mar 2025 21:39:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461233 Receipts under a Cost Contribution Agreement for general business support services were held not to constitute fees for technical services under the Income-tax Act, 1961 or Article 13 of the India-UK DTAA. The Tribunal applied the jurisdictional High Court's ruling that the same services were managerial in nature and did not make available technical knowledge, skill, experience, know-how or processes to the Indian entity. Mere use of expertise in rendering management, marketing, legal, financial, taxation, HR and procurement support was insufficient to characterise the receipts as technical fees. The addition was therefore deleted. Case-Laws Income Tax Tue, 10 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461233