Make available test under India-UK DTAA: managerial business support services were not fees for technical services

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....Finance Act 2025 amendment rendered the challenge to the validity of the assessment infructuous. On taxability of receipts under the India-UK DTAA, the Tribunal held that general business support services rendered under a cost contribution agreement were managerial in nature and did not make available technical knowledge, experience, skill or know-how to the Indian recipient; the receipts were therefore not fees for technical services. It also directed recomputation of interest for the relief granted in appeal.....