https://www.taxtmi.com/caselaws?id=779846 Income from group services rendered outside India was treated as fees for technical services under Article 12 of the India-Finland DTAA, with the Tribunal following its earlier decisions in the assessee's own case and connected matters and rejecting the argument that performance outside India changed the treaty position. Guarantee fee received outside India was also held taxable in India, as the Tribunal found no independent guarantee business distinct from the subsidiary-related arrangement and applied the relevant treaty framework for income not otherwise dealt with, while the absence of a permanent establishment did not alter the result on the facts. The additions were sustained on both grounds. en-us Mon, 25 Aug 2025 00:00:00 +0530 Tue, 14 Oct 2025 09:39:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779846 Income from group services rendered outside India was treated as fees for technical services under Article 12 of the India-Finland DTAA, with the Tribunal following its earlier decisions in the assessee's own case and connected matters and rejecting the argument that performance outside India changed the treaty position. Guarantee fee received outside India was also held taxable in India, as the Tribunal found no independent guarantee business distinct from the subsidiary-related arrangement and applied the relevant treaty framework for income not otherwise dealt with, while the absence of a permanent establishment did not alter the result on the facts. The additions were sustained on both grounds. Case-Laws Income Tax Mon, 25 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779846