https://www.taxtmi.com/highlights?id=95208 Receipts from providing in-flight entertainment content to an Indian airline were assessed as fees for technical services under section 9(1)(vii) and Article 13 of the India-UK DTAA. Applying Article 13(4)(c), the "make available" condition required the payer to receive technical knowledge, experience, skill, know-how, or processes enabling independent application. As the Revenue failed to establish any transfer of know-how or technical knowledge to the payer, the consideration for supplying content did not constitute FTS, rendering the corresponding addition unsustainable and warranting deletion. - ITAT en-us Fri, 19 Dec 2025 08:30:26 +0530 Fri, 19 Dec 2025 08:30:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=95208 Receipts from providing in-flight entertainment content to an Indian airline were assessed as fees for technical services under section 9(1)(vii) and Article 13 of the India-UK DTAA. Applying Article 13(4)(c), the "make available" condition required the payer to receive technical knowledge, experience, skill, know-how, or processes enabling independent application. As the Revenue failed to establish any transfer of know-how or technical knowledge to the payer, the consideration for supplying content did not constitute FTS, rendering the corresponding addition unsustainable and warranting deletion. - ITAT Highlights Income Tax Fri, 19 Dec 2025 08:30:26 +0530 https://www.taxtmi.com/highlights?id=95208