https://www.taxtmi.com/caselaws?id=466525 Under Article 13 of the India-UK tax treaty, IT support and related services are taxable as fees for technical services only if they make available technical knowledge, experience, skill, know-how or processes to the recipient for independent future use; because the services were recurring support services and no such enabling transfer was shown, the receipts were not taxable. Cost-to-cost reimbursements from the associated enterprise were also not taxable because no separate income or profit element was established, so the additions were not sustained. en-us Thu, 27 Feb 2025 00:00:00 +0530 Mon, 09 Feb 2026 15:25:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466525 Under Article 13 of the India-UK tax treaty, IT support and related services are taxable as fees for technical services only if they make available technical knowledge, experience, skill, know-how or processes to the recipient for independent future use; because the services were recurring support services and no such enabling transfer was shown, the receipts were not taxable. Cost-to-cost reimbursements from the associated enterprise were also not taxable because no separate income or profit element was established, so the additions were not sustained. Case-Laws Income Tax Thu, 27 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466525