https://www.taxtmi.com/caselaws?id=462000 Consulting and engineering service receipts were held not taxable as fees for technical services or royalty under the India-UK DTAA and the Act because the treaty "make available" condition was not satisfied; common cost recharge, being ancillary to those services, was likewise not separately taxable in the absence of a permanent establishment in India. A concessional tax rate claim on interest income, raised for the first time before the Dispute Resolution Panel, was treated as a legal claim not requiring fresh evidence and was remanded to the Assessing Officer for fresh adjudication after hearing the assessee. en-us Wed, 27 Sep 2023 00:00:00 +0530 Wed, 14 May 2025 19:05:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462000 Consulting and engineering service receipts were held not taxable as fees for technical services or royalty under the India-UK DTAA and the Act because the treaty "make available" condition was not satisfied; common cost recharge, being ancillary to those services, was likewise not separately taxable in the absence of a permanent establishment in India. A concessional tax rate claim on interest income, raised for the first time before the Dispute Resolution Panel, was treated as a legal claim not requiring fresh evidence and was remanded to the Assessing Officer for fresh adjudication after hearing the assessee. Case-Laws Income Tax Wed, 27 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462000