https://www.taxtmi.com/caselaws?id=772130 Aircraft repair and maintenance receipts were outside fees for included services under section 9(1)(vii) and Article 12(4) of the India-US DTAA because the work did not make available technical knowledge, skill, know-how, process or technical design to the recipient for independent future use. The make available test requires more than technically skilled services or an incidental benefit; the recipient must be able to apply the technology on its own after the contract ends. Reimbursement-style corporate allocation charges were also not taxable, as the factual findings showed reimbursement of actual expenses without any technical or consultancy service, training, or transfer of operational knowledge to the Indian entity. en-us Fri, 23 May 2025 00:00:00 +0530 Wed, 04 Jun 2025 08:40:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772130 Aircraft repair and maintenance receipts were outside fees for included services under section 9(1)(vii) and Article 12(4) of the India-US DTAA because the work did not make available technical knowledge, skill, know-how, process or technical design to the recipient for independent future use. The make available test requires more than technically skilled services or an incidental benefit; the recipient must be able to apply the technology on its own after the contract ends. Reimbursement-style corporate allocation charges were also not taxable, as the factual findings showed reimbursement of actual expenses without any technical or consultancy service, training, or transfer of operational knowledge to the Indian entity. Case-Laws Income Tax Fri, 23 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772130