https://www.taxtmi.com/caselaws?id=465979 Routine support and administrative services in marketing, human resources, finance, information technology, legal, commercial affairs and facilities management were held not to be fee for technical services under the India-UK DTAA. The treaty's make available test was not satisfied because the recipient was not shown to have been enabled to apply technical knowledge, skill, experience or know-how independently in future without further recourse to the service provider. Mere assistance, standard guidance, efficiency enhancement or incidental benefit was insufficient. The receipt for these services was therefore not taxable as fee for technical services under Article 13(4)(c), and the issue was decided in favour of the assessee. en-us Wed, 07 Aug 2024 00:00:00 +0530 Thu, 15 Jan 2026 12:46:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465979 Routine support and administrative services in marketing, human resources, finance, information technology, legal, commercial affairs and facilities management were held not to be fee for technical services under the India-UK DTAA. The treaty's make available test was not satisfied because the recipient was not shown to have been enabled to apply technical knowledge, skill, experience or know-how independently in future without further recourse to the service provider. Mere assistance, standard guidance, efficiency enhancement or incidental benefit was insufficient. The receipt for these services was therefore not taxable as fee for technical services under Article 13(4)(c), and the issue was decided in favour of the assessee. Case-Laws Income Tax Wed, 07 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465979