India Management Fees & IC Labour Charges: Not "Fees for Technical Services" Under Article 12(4)(b); No Enduring Benefit Found.

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....Income accrued in India - treatment to management fee and IC Labour Charges as fee for technical services/fee for included services - FTS / FIS - These services have not resulted in any enduring benefit to Everest India by way of any knowledge which could be applied by it on its own in future without depending on the assessee. These are general managerial services which are received by the assessee on recurring basis. Therefore, the test laid down under Article 12(4)(b), in our considered view, are not satisfied in the present factual scenario. - AT....