https://www.taxtmi.com/caselaws?id=468128 Under the India-UK DTAA, underwriting commission and selling commission received from Indian companies were held not to be fees for technical services because the relevant services were not made available in the treaty sense. The assessee was entitled to rely on the more beneficial treaty position under section 90(2), and the Tribunal followed its earlier view that such commission receipts fall outside FTS. The income was therefore treated as business income, not taxable in India in the absence of attribution to a permanent establishment. en-us Tue, 30 Aug 2011 00:00:00 +0530 Fri, 17 Apr 2026 17:06:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468128 Under the India-UK DTAA, underwriting commission and selling commission received from Indian companies were held not to be fees for technical services because the relevant services were not made available in the treaty sense. The assessee was entitled to rely on the more beneficial treaty position under section 90(2), and the Tribunal followed its earlier view that such commission receipts fall outside FTS. The income was therefore treated as business income, not taxable in India in the absence of attribution to a permanent establishment. Case-Laws Income Tax Tue, 30 Aug 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468128