https://www.taxtmi.com/highlights?id=89193 HC allowed the petitioner's application under Section 197, ruling that cross-cost charges from associated enterprises do not constitute technical services or royalties under India-UK DTAA. The court found no transfer of technical knowledge, rights, or software copyrights, thereby rejecting the Assessing Officer's taxation claim. The HC directed the AO to issue a 'nil' withholding tax certificate, emphasizing that the services did not satisfy the conditions for Fees for Technical Services (FTS) or royalty provisions. en-us Sat, 07 Jun 2025 08:32:51 +0530 Sat, 07 Jun 2025 08:32:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=89193 HC allowed the petitioner's application under Section 197, ruling that cross-cost charges from associated enterprises do not constitute technical services or royalties under India-UK DTAA. The court found no transfer of technical knowledge, rights, or software copyrights, thereby rejecting the Assessing Officer's taxation claim. The HC directed the AO to issue a 'nil' withholding tax certificate, emphasizing that the services did not satisfy the conditions for Fees for Technical Services (FTS) or royalty provisions. Highlights Income Tax Sat, 07 Jun 2025 08:32:51 +0530 https://www.taxtmi.com/highlights?id=89193