https://www.taxtmi.com/caselaws?id=801073 Automated subscription, training and support services do not constitute fees for technical services under Article 12(5)(b) of the India-Netherlands tax treaty or section 9(1)(vii) of the Income-tax Act where they merely provide access to software systems. The make-available requirement is not met when software is hosted outside India, no unrebutted evidence establishes human intervention, and the recipient receives only a standard facility and a right to use the systems. Training and support limited to system use, without transfer of underlying technology or capability for independent future application, likewise do not transfer technical knowledge, skill, know-how or processes. en-us Tue, 29 Sep 2026 00:00:00 +0530 Thu, 15 Oct 2026 05:44:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801073 Automated subscription, training and support services do not constitute fees for technical services under Article 12(5)(b) of the India-Netherlands tax treaty or section 9(1)(vii) of the Income-tax Act where they merely provide access to software systems. The make-available requirement is not met when software is hosted outside India, no unrebutted evidence establishes human intervention, and the recipient receives only a standard facility and a right to use the systems. Training and support limited to system use, without transfer of underlying technology or capability for independent future application, likewise do not transfer technical knowledge, skill, know-how or processes. Case-Laws Income Tax Tue, 29 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801073