https://www.taxtmi.com/caselaws?id=796332 Independent diamond grading and certification that provides factual reports on cut, colour, clarity and carat weight does not constitute managerial, technical or consultancy services merely because the provider uses specialised personnel or equipment. Such services do not transfer grading methodology, scientific standards, processes or know-how to the payer and therefore fail the "make available" requirement for fees for included services under the India-USA and India-UK tax treaties. Payments to non-resident grading entities are consequently not taxable as fees for technical services; where no other Indian taxable nexus exists, no tax deduction obligation arises and consequential interest is not payable. 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 that provides factual reports on cut, colour, clarity and carat weight does not constitute managerial, technical or consultancy services merely because the provider uses specialised personnel or equipment. Such services do not transfer grading methodology, scientific standards, processes or know-how to the payer and therefore fail the "make available" requirement for fees for included services under the India-USA and India-UK tax treaties. Payments to non-resident grading entities are consequently not taxable as fees for technical services; where no other Indian taxable nexus exists, no tax deduction obligation arises and consequential interest is not payable. Case-Laws Income Tax Thu, 30 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796332