Global operation fees not taxable as FTS under India-UK DTAA

UK Grid Solution Limited Vs DCIT (ITAT Delhi) Global operation fees not taxable as FTS under India-UK DTAA as ‘make available’ clause in Article 13(4)(c) not satisfied ITAT Delhi held that global operation fees cannot be taxed as Fees for Technical Services (FTS) under the provisions of the Act and the India-UK DTAA as it doesn’t satisfy the ‘make available’ clause contained in Article 13(4)(c) of the India-UK DTAA. Facts- The assessee appellant is a foreign company incorporated in the United Kingdom and a tax resident of that country in terms of Article 4 of the India-UK Double Taxa...