https://www.taxtmi.com/caselaws?id=791104 Manpower support service receipts from an Indian group entity were held not to be fees for technical services under section 9(1)(vii) or Article 12(4) of the India-USA DTAA because the arrangement did not transfer technical knowledge, experience, skill, know-how, or processes. The make available condition was not satisfied, as the services amounted only to support and facilitation from outside India. In the absence of any fresh material or distinguishing facts from the immediately preceding year's identical arrangement, the same view was followed and the addition on this ground was deleted. en-us Fri, 24 Apr 2026 00:00:00 +0530 Wed, 06 May 2026 08:32:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791104 Manpower support service receipts from an Indian group entity were held not to be fees for technical services under section 9(1)(vii) or Article 12(4) of the India-USA DTAA because the arrangement did not transfer technical knowledge, experience, skill, know-how, or processes. The make available condition was not satisfied, as the services amounted only to support and facilitation from outside India. In the absence of any fresh material or distinguishing facts from the immediately preceding year's identical arrangement, the same view was followed and the addition on this ground was deleted. Case-Laws Income Tax Fri, 24 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791104