https://www.taxtmi.com/caselaws?id=461989 Consulting and engineering receipts fall outside fees for technical services under the India-UK treaty where project-specific drawings and designs do not enable the recipient to independently use the underlying technology. Article 13(4)(c) requires technical knowledge, experience, skill, know-how or processes to be made available; developing and transferring a technical plan or design remains subject to that condition. Such receipts constitute business profits and are not taxable in India without a permanent establishment. Management fees and common cost recharges consequential to those services are likewise neither royalty nor fees for technical services where no technical capability is made available, and remain untaxable absent 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 Consulting and engineering receipts fall outside fees for technical services under the India-UK treaty where project-specific drawings and designs do not enable the recipient to independently use the underlying technology. Article 13(4)(c) requires technical knowledge, experience, skill, know-how or processes to be made available; developing and transferring a technical plan or design remains subject to that condition. Such receipts constitute business profits and are not taxable in India without a permanent establishment. Management fees and common cost recharges consequential to those services are likewise neither royalty nor fees for technical services where no technical capability is made available, and remain untaxable absent a permanent establishment. Case-Laws Income Tax Thu, 13 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461989