https://www.taxtmi.com/caselaws?id=769217 TDS credit was to be allowed after verification under the matching provisions, as the mismatch was not sustained on merits. The service receipts were examined under the India-USA DTAA and were treated as fees for technical services under domestic law, but treaty protection depended on the make available condition. Because the services did not transfer technical knowledge, skill, know-how, or processes enabling the recipient to act independently, the receipts were not taxable in India under the treaty and the addition was deleted. Consequential relief followed on the tax credit issue. en-us Wed, 16 Apr 2025 00:00:00 +0530 Fri, 18 Apr 2025 13:26:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769217 TDS credit was to be allowed after verification under the matching provisions, as the mismatch was not sustained on merits. The service receipts were examined under the India-USA DTAA and were treated as fees for technical services under domestic law, but treaty protection depended on the make available condition. Because the services did not transfer technical knowledge, skill, know-how, or processes enabling the recipient to act independently, the receipts were not taxable in India under the treaty and the addition was deleted. Consequential relief followed on the tax credit issue. Case-Laws Income Tax Wed, 16 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769217