https://www.taxtmi.com/caselaws?id=463258 Management fees for functional and human-resource support remained taxable as fees for technical services because the Most Favoured Nation clause in the India-France DTAA could not import the India-UK DTAA's make-available requirement without a separate notification. Corporate guarantee fees were not fees for technical services, as providing a guarantee for an associated enterprise's borrowing is not managerial, technical or consultancy service. Social security contribution reimbursements remained taxable where linked to services, notwithstanding cost-to-cost treatment without markup. Surcharge and education cess could not be separately levied where the treaty rate covered Indian income-tax, including surcharge and substantially similar later taxes. en-us Fri, 03 May 2024 00:00:00 +0530 Tue, 19 Aug 2025 21:13:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463258 Management fees for functional and human-resource support remained taxable as fees for technical services because the Most Favoured Nation clause in the India-France DTAA could not import the India-UK DTAA's make-available requirement without a separate notification. Corporate guarantee fees were not fees for technical services, as providing a guarantee for an associated enterprise's borrowing is not managerial, technical or consultancy service. Social security contribution reimbursements remained taxable where linked to services, notwithstanding cost-to-cost treatment without markup. Surcharge and education cess could not be separately levied where the treaty rate covered Indian income-tax, including surcharge and substantially similar later taxes. Case-Laws Income Tax Fri, 03 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463258