https://www.taxtmi.com/caselaws?id=790123 Routine intra-group support services were held not to constitute fees for technical services under Article 13 of the India-UK DTAA because the services did not make available technical knowledge, experience, skill, know-how or processes to the Indian entity. The parent company retained control and supervision over marketing and scientific know-how, and the Indian entity received no transfer of technical skill in the treaty sense. Any incidental learning by employees while following instructions was insufficient to meet the make available requirement. The finding that no technical knowledge or skill was imparted was treated as factual, and no perversity was shown; the receipts therefore were not taxable as technical services. en-us Fri, 10 Apr 2026 00:00:00 +0530 Mon, 20 Apr 2026 08:30:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790123 Routine intra-group support services were held not to constitute fees for technical services under Article 13 of the India-UK DTAA because the services did not make available technical knowledge, experience, skill, know-how or processes to the Indian entity. The parent company retained control and supervision over marketing and scientific know-how, and the Indian entity received no transfer of technical skill in the treaty sense. Any incidental learning by employees while following instructions was insufficient to meet the make available requirement. The finding that no technical knowledge or skill was imparted was treated as factual, and no perversity was shown; the receipts therefore were not taxable as technical services. Case-Laws Income Tax Fri, 10 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790123