https://www.taxtmi.com/caselaws?id=779777 Payment to a non-resident procurement agent for arranging merchandise for duty-free shops was analysed as a commercial sourcing arrangement, not fees for technical services under section 9(1)(vii) or Article 13 of the India-UK DTAA. No clause transferred technical knowledge, skill, know-how, or technical design, and the non-resident did not make any such input available for the assessee's independent future use. The make available condition was therefore not satisfied, and the payment was not chargeable to tax in India as fees for technical services. en-us Tue, 23 Sep 2025 00:00:00 +0530 Mon, 13 Oct 2025 08:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779777 Payment to a non-resident procurement agent for arranging merchandise for duty-free shops was analysed as a commercial sourcing arrangement, not fees for technical services under section 9(1)(vii) or Article 13 of the India-UK DTAA. No clause transferred technical knowledge, skill, know-how, or technical design, and the non-resident did not make any such input available for the assessee's independent future use. The make available condition was therefore not satisfied, and the payment was not chargeable to tax in India as fees for technical services. Case-Laws Income Tax Tue, 23 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779777