https://www.taxtmi.com/caselaws?id=780048 Repair and maintenance receipts for aircraft engines were held not to constitute fees for technical services because the treaty test under Article 12 required that technical knowledge, skill, know-how or processes be made available to the recipient. The services showed performance of specialised work for customers, but the record did not show any transfer of technology or ability for the customers to independently carry out the repair and maintenance themselves in future. Applying the cited binding and coordinate bench authorities, the Tribunal excluded the receipts from FTS treatment and deleted the addition. en-us Mon, 06 Oct 2025 00:00:00 +0530 Fri, 17 Oct 2025 08:08:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780048 Repair and maintenance receipts for aircraft engines were held not to constitute fees for technical services because the treaty test under Article 12 required that technical knowledge, skill, know-how or processes be made available to the recipient. The services showed performance of specialised work for customers, but the record did not show any transfer of technology or ability for the customers to independently carry out the repair and maintenance themselves in future. Applying the cited binding and coordinate bench authorities, the Tribunal excluded the receipts from FTS treatment and deleted the addition. Case-Laws Income Tax Mon, 06 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780048