https://www.taxtmi.com/caselaws?id=461989 Under Article 13(4)(c) of the India-UK tax treaty, consulting and engineering receipts are taxable as fees for technical services only if the services make available technical knowledge, experience, skill, know-how or processes. The article states that the make-available test was not met where drawings and designs were project-specific and did not enable the recipient to independently apply the underlying technology later, so the receipts were treated as business profits and not taxable in India absent a permanent establishment. It further states that management fees and common cost recharge did not constitute royalty or fees for technical services on the same reasoning and were likewise not taxable in India without a permanent establishment. en-us Thu, 13 Jul 2023 00:00:00 +0530 Tue, 13 May 2025 19:23:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461989 Under Article 13(4)(c) of the India-UK tax treaty, consulting and engineering receipts are taxable as fees for technical services only if the services make available technical knowledge, experience, skill, know-how or processes. The article states that the make-available test was not met where drawings and designs were project-specific and did not enable the recipient to independently apply the underlying technology later, so the receipts were treated as business profits and not taxable in India absent a permanent establishment. It further states that management fees and common cost recharge did not constitute royalty or fees for technical services on the same reasoning and were likewise not taxable in India without a permanent establishment. Case-Laws Income Tax Thu, 13 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461989