https://www.taxtmi.com/caselaws?id=468132 Under the India-UK DTAA, underwriting commission and reimbursement of expenses received for GDR/FCCB issuance were not taxable in India as fees for technical services because the services were not made available to the Indian recipient. The tribunal applied section 90(2) of the Income-tax Act, 1961 and the treaty's more beneficial provisions, following the earlier Raymond Ltd. line of reasoning that such investment banking receipts fall outside the treaty definition of fees for technical services. The Revenue's challenge failed, and the addition was not sustained. en-us Thu, 13 Apr 2017 00:00:00 +0530 Fri, 17 Apr 2026 15:27:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468132 Under the India-UK DTAA, underwriting commission and reimbursement of expenses received for GDR/FCCB issuance were not taxable in India as fees for technical services because the services were not made available to the Indian recipient. The tribunal applied section 90(2) of the Income-tax Act, 1961 and the treaty's more beneficial provisions, following the earlier Raymond Ltd. line of reasoning that such investment banking receipts fall outside the treaty definition of fees for technical services. The Revenue's challenge failed, and the addition was not sustained. Case-Laws Income Tax Thu, 13 Apr 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468132