https://www.taxtmi.com/caselaws?id=772384 Cross-charges for corporate, managerial, oversight, support and coordination services were not fees for technical services because no technical knowledge, experience, skill, know-how or process was made available to the recipient under the India-UK DTAA. Mere specialized support or incidental benefit was insufficient. The receipts also did not constitute royalty, as there was no material showing that the recipient acquired copyright or comparable rights in software or tools. On that basis, the nil withholding tax certificate was upheld and the impugned refusal was set aside, with the tax authority directed to issue the certificate. en-us Tue, 20 May 2025 00:00:00 +0530 Sat, 07 Jun 2025 08:32:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772384 Cross-charges for corporate, managerial, oversight, support and coordination services were not fees for technical services because no technical knowledge, experience, skill, know-how or process was made available to the recipient under the India-UK DTAA. Mere specialized support or incidental benefit was insufficient. The receipts also did not constitute royalty, as there was no material showing that the recipient acquired copyright or comparable rights in software or tools. On that basis, the nil withholding tax certificate was upheld and the impugned refusal was set aside, with the tax authority directed to issue the certificate. Case-Laws Income Tax Tue, 20 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772384