https://www.taxtmi.com/caselaws?id=796332 Independent diamond grading and certification is described as factual evaluation of an existing product, not managerial, technical or consultancy services, because it provides neither technical advice nor manufacturing assistance, methodology or know-how. Specialised personnel or equipment used by the provider does not alone make the service technical in the recipient's hands. Under the India-USA and India-UK treaties, the payments do not meet the make-available requirement because grading reports do not enable the payer to independently apply the provider's expertise in future. The notes further state that payments to Thailand and Hong Kong entities lacked Indian tax chargeability or taxable nexus, so no withholding obligation arose. en-us Thu, 30 Jul 2026 00:00:00 +0530 Tue, 04 Aug 2026 08:39:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796332 Independent diamond grading and certification is described as factual evaluation of an existing product, not managerial, technical or consultancy services, because it provides neither technical advice nor manufacturing assistance, methodology or know-how. Specialised personnel or equipment used by the provider does not alone make the service technical in the recipient's hands. Under the India-USA and India-UK treaties, the payments do not meet the make-available requirement because grading reports do not enable the payer to independently apply the provider's expertise in future. The notes further state that payments to Thailand and Hong Kong entities lacked Indian tax chargeability or taxable nexus, so no withholding obligation arose. Case-Laws Income Tax Thu, 30 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796332