https://www.taxtmi.com/caselaws?id=468129 Investment banking receipts and expense reimbursements were treated as not taxable in India as fees for technical services under the India-UK treaty because the services did not satisfy the make-available test; the Tribunal applied the principle that technical knowledge, skill, experience or know-how must be made available to the recipient. Interest income was directed to be taxed at the treaty rate once treaty protection applied. Consequential interest under sections 234B and 234D was required to be recomputed after giving effect to the revised tax treatment. The alleged refund-related demand was remanded to the Assessing Officer for factual verification before relief could be granted. en-us Thu, 13 Mar 2014 00:00:00 +0530 Fri, 17 Apr 2026 13:06:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468129 Investment banking receipts and expense reimbursements were treated as not taxable in India as fees for technical services under the India-UK treaty because the services did not satisfy the make-available test; the Tribunal applied the principle that technical knowledge, skill, experience or know-how must be made available to the recipient. Interest income was directed to be taxed at the treaty rate once treaty protection applied. Consequential interest under sections 234B and 234D was required to be recomputed after giving effect to the revised tax treatment. The alleged refund-related demand was remanded to the Assessing Officer for factual verification before relief could be granted. Case-Laws Income Tax Thu, 13 Mar 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468129