https://www.taxtmi.com/caselaws?id=780502 Receipts from group support services were not taxable as fees for technical services because the services, assessed from the functional agreement and actual activities, were found to be standardised support functions rather than predominantly managerial, technical or consultancy services. The expressions "managerial", "technical" and "consultancy" were read in their ordinary commercial sense, requiring control or administration, special technical skill, or advisory expertise with human interface. On the material available, the services and access to centralised systems did not show that the Indian entities were managed or that the receipts wholly fell within Article 12(3)(b) of the India-Belgium DTAA or section 9(1)(vii). en-us Mon, 27 Oct 2025 00:00:00 +0530 Fri, 31 Oct 2025 08:23:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780502 Receipts from group support services were not taxable as fees for technical services because the services, assessed from the functional agreement and actual activities, were found to be standardised support functions rather than predominantly managerial, technical or consultancy services. The expressions "managerial", "technical" and "consultancy" were read in their ordinary commercial sense, requiring control or administration, special technical skill, or advisory expertise with human interface. On the material available, the services and access to centralised systems did not show that the Indian entities were managed or that the receipts wholly fell within Article 12(3)(b) of the India-Belgium DTAA or section 9(1)(vii). Case-Laws Income Tax Mon, 27 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780502