India- UK DTAA –Routine managerial services not in nature of technical services, not makes available any technical knowledge having enduring benefits – AAR

Brief of the Case Authority for Advance Rulings held In the case of Measurement Technology Limited, UK that the services under agreement No.1 relate to review by Group operation Director and general guidance given by him on financial, operational, human resource, setting up targets and performance appraisal related matters. He is providing these services from the UK mainly, his visits during a year are generally for short duration having aggregate number of days of visit in a year never exceeding 30 days. The applicant has provided sample e-mails sent by him to MTL India which show that his s...