India Finland DTA- Technical services if technical knowledge skill, know how or design been made available

Advertisement Brief of Case: ITAT Delhi has held in the case of ITO, TDS vs. Nokia India Pvt. Ltd that services rendered does not qualify as FTS for technical services under the India Finland Tax Treaty if service provider has not made available to assessee any technical knowledge skill, know how, Technical Design etc. Services can be considered to be made available by provider only where the services leads to transfer/imparting of technical knowledge, experience, skills know-how, or processes to the recipient. Brief Facts and Question of Law: Brief Facts of the Assessee: The Assessee Compa...