Archive: 24 January 2011

Amounts receivable by a British company (EMEIA) from the applicant under the Area Services & Market Development Agreement not liable to be taxed under the I-T Act as fee for `included services’ or as business profits under Indo-UK Treaty

Dissemination of informations, furnishing guidelines and suggesting plans of action aimed at uniformity and seamless quality in business dealings of participating group entities do not per se amount to making available to them technical knowledge and experience possessed by EMEIA to a substantial extent; There is no transfer of technical know-how in that pro