https://www.taxtmi.com/caselaws?id=770540 Receipts from consulting engineering services, management fees and common cost recharge were held not taxable in India as fees for technical services under the India-UK tax treaty or the Income-tax Act because the services did not make available technical knowledge, experience, skill, know-how or processes to the Indian recipient. The management fee and recharge were treated as ancillary to the same service arrangement and could not be taxed differently. In the absence of a permanent establishment in India, the receipts were characterised as business profits under Article 7 and not taxable in India; the additions were deleted in favour of the assessee. en-us Wed, 23 Apr 2025 00:00:00 +0530 Mon, 12 May 2025 15:34:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770540 Receipts from consulting engineering services, management fees and common cost recharge were held not taxable in India as fees for technical services under the India-UK tax treaty or the Income-tax Act because the services did not make available technical knowledge, experience, skill, know-how or processes to the Indian recipient. The management fee and recharge were treated as ancillary to the same service arrangement and could not be taxed differently. In the absence of a permanent establishment in India, the receipts were characterised as business profits under Article 7 and not taxable in India; the additions were deleted in favour of the assessee. Case-Laws Income Tax Wed, 23 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770540