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    <title>2025 (4) TMI 214 - ITAT DELHI</title>
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    <description>Routine IT support services were treated as taxable in India only if they made available technical knowledge, experience, skill, know-how or processes so the recipient could apply them independently after the contract ended. On the facts described, the Tribunal found that the Indian recipient was not enabled to perform the work on its own, and training on common office software did not amount to specialised knowledge being made available. The Tribunal also accepted that the amounts were reimbursed on a cost-to-cost basis without a profit element, and that factual position was not rebutted. The receipts were therefore held not taxable as fees for technical services or fees for included services, and the additions were deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=768300</link>
      <description>Routine IT support services were treated as taxable in India only if they made available technical knowledge, experience, skill, know-how or processes so the recipient could apply them independently after the contract ended. On the facts described, the Tribunal found that the Indian recipient was not enabled to perform the work on its own, and training on common office software did not amount to specialised knowledge being made available. The Tribunal also accepted that the amounts were reimbursed on a cost-to-cost basis without a profit element, and that factual position was not rebutted. The receipts were therefore held not taxable as fees for technical services or fees for included services, and the additions were deleted.</description>
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