https://www.taxtmi.com/caselaws?id=769517 ITAT Ahmedabad ruled that various services including CHR Recruitment Fees, External Information Services, Real Estate Corporate Travel Services, Health Ecotox Services, and IT Services provided by a Netherlands entity did not qualify as Fee for Technical Services under section 9(1)(vii) and Article 12 of the India-Netherlands Tax Treaty. The tribunal held that the "make available" condition was not satisfied as the Department failed to demonstrate that technology was made available to service recipients, thereby excluding these services from FTS definition and Indian tax liability. en-us Tue, 15 Apr 2025 00:00:00 +0530 Sat, 26 Apr 2025 08:30:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769517 ITAT Ahmedabad ruled that various services including CHR Recruitment Fees, External Information Services, Real Estate Corporate Travel Services, Health Ecotox Services, and IT Services provided by a Netherlands entity did not qualify as Fee for Technical Services under section 9(1)(vii) and Article 12 of the India-Netherlands Tax Treaty. The tribunal held that the "make available" condition was not satisfied as the Department failed to demonstrate that technology was made available to service recipients, thereby excluding these services from FTS definition and Indian tax liability. Case-Laws Income Tax Tue, 15 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769517