https://www.taxtmi.com/caselaws?id=780940 Receipts for IT support and non-IT support services were held not taxable as fee for technical services under Article 13 of the India-UK DTAA because the make available test was not satisfied. The record did not show any transfer of technical knowledge, skill, know-how or process enabling the Indian recipient to independently perform the services after receipt. For the IT support functions, the distinction drawn from later development activity did not establish make available. For the non-IT support functions, routine group services in human resources, finance, legal, compliance and secretarial matters likewise involved no independent transfer of capability, so the additions were deleted. en-us Tue, 04 Nov 2025 00:00:00 +0530 Sat, 08 Nov 2025 08:30:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780940 Receipts for IT support and non-IT support services were held not taxable as fee for technical services under Article 13 of the India-UK DTAA because the make available test was not satisfied. The record did not show any transfer of technical knowledge, skill, know-how or process enabling the Indian recipient to independently perform the services after receipt. For the IT support functions, the distinction drawn from later development activity did not establish make available. For the non-IT support functions, routine group services in human resources, finance, legal, compliance and secretarial matters likewise involved no independent transfer of capability, so the additions were deleted. Case-Laws Income Tax Tue, 04 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780940