https://www.taxtmi.com/caselaws?id=464624 ITAT Del. dismissed the Revenue's appeal, holding that payments by the assessee to its non-resident group company for IT support services did not meet the "make available" test under Article 13 of the India-UK DTAA and therefore did not constitute fees for technical services. The tribunal followed its earlier view that no technical know-how, skill or transfer was imparted to the assessee. The orders passed under s.143(3) r.w.s.144B and s.143(3) were found valid in light of this conclusion. en-us Thu, 07 Nov 2024 00:00:00 +0530 Thu, 06 Nov 2025 19:04:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464624 ITAT Del. dismissed the Revenue's appeal, holding that payments by the assessee to its non-resident group company for IT support services did not meet the "make available" test under Article 13 of the India-UK DTAA and therefore did not constitute fees for technical services. The tribunal followed its earlier view that no technical know-how, skill or transfer was imparted to the assessee. The orders passed under s.143(3) r.w.s.144B and s.143(3) were found valid in light of this conclusion. Case-Laws Income Tax Thu, 07 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464624