https://www.taxtmi.com/caselaws?id=461763 Background screening and investigation receipts under the India-UK DTAA were treated as neither royalty nor fees for technical services because the activity was limited to collecting and validating factual information and issuing screening reports for internal client use. The reports did not involve use of copyright, access to a database, or imparting technical knowledge, experience, skill, know-how or processes, and therefore did not satisfy the make-available requirement. The assessment addition based on that characterisation was unsustainable, and the receipts were held not taxable on that basis. en-us Thu, 27 Jun 2024 00:00:00 +0530 Fri, 25 Apr 2025 18:56:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461763 Background screening and investigation receipts under the India-UK DTAA were treated as neither royalty nor fees for technical services because the activity was limited to collecting and validating factual information and issuing screening reports for internal client use. The reports did not involve use of copyright, access to a database, or imparting technical knowledge, experience, skill, know-how or processes, and therefore did not satisfy the make-available requirement. The assessment addition based on that characterisation was unsustainable, and the receipts were held not taxable on that basis. Case-Laws Income Tax Thu, 27 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461763