Case Law Details
Case Name : Director of Income Tax Vs Guy Carpenter & Co. Ltd. (Delhi High Court)
Related Assessment Year :
Courts :
All High Courts Delhi High Court
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To make available technical knowledge, mere provision of service not enough; the payer must be enabled to perform the service himself
Honourable High court has agreed with the The Tribunal that the ‘make available’ condition was not satisfied inasmuch as no technical knowledge etc, was made available by the assessee to the Indian insurance companies operating in India. The Tribunal conclusions are based on an assessment of the factual matrix of the case at hand and are factual in nature. As there is no perversity in the findings, it does not give rise to a substantial question ...
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Though definition of ‘make available service’ is precise but write up is quite lenghy.