https://www.taxtmi.com/caselaws?id=769734 Under the India-UK DTAA, managerial and business support services under a cost contribution arrangement were not fees for technical services because they did not make available technical knowledge, experience, skill, know-how or processes; the addition was deleted. Receipts for access to maintenance software were not royalty because the payment was for a copyrighted article and not for rights in the copyright itself; the addition was deleted. The TDS credit claim was to be verified against Form 16A and income records, and interest under section 234A was to be recomputed on the correct delay period; these matters were restored for verification and recalculation. en-us Tue, 07 Jan 2025 00:00:00 +0530 Thu, 01 May 2025 08:46:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769734 Under the India-UK DTAA, managerial and business support services under a cost contribution arrangement were not fees for technical services because they did not make available technical knowledge, experience, skill, know-how or processes; the addition was deleted. Receipts for access to maintenance software were not royalty because the payment was for a copyrighted article and not for rights in the copyright itself; the addition was deleted. The TDS credit claim was to be verified against Form 16A and income records, and interest under section 234A was to be recomputed on the correct delay period; these matters were restored for verification and recalculation. Case-Laws Income Tax Tue, 07 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769734