https://www.taxtmi.com/caselaws?id=468789 Receipts from software licence-related implementation, enhancement, maintenance, consultancy and training services were treated as non-taxable Fees for Technical Services under the India-UK DTAA because the Revenue did not prove that technical knowledge, experience or know-how was made available for independent use. Ancillary support linked to software utilisation did not, by itself, satisfy the make available test. Reimbursed travelling and lodging expenses were also not sustained as FTS on the facts recorded, especially where the matter had already been remanded for verification. The impugned additions on both heads were therefore not sustained. en-us Tue, 16 Jul 2024 00:00:00 +0530 Wed, 20 May 2026 19:00:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468789 Receipts from software licence-related implementation, enhancement, maintenance, consultancy and training services were treated as non-taxable Fees for Technical Services under the India-UK DTAA because the Revenue did not prove that technical knowledge, experience or know-how was made available for independent use. Ancillary support linked to software utilisation did not, by itself, satisfy the make available test. Reimbursed travelling and lodging expenses were also not sustained as FTS on the facts recorded, especially where the matter had already been remanded for verification. The impugned additions on both heads were therefore not sustained. Case-Laws Income Tax Tue, 16 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468789