India- UK DTAA – Supply Management Services by UK company not in the nature of fee for technical services or royalties – AAR

Brief of the Case Authority for Advance Rulings held In the case of Cummins Limited, UK that the agreement shows that the CTIL, a company incorporated in India is working with the applicant only to ensure market competitive pricing from the suppliers. The applicant maintains contract supply agreement with suppliers after identifying the products availability, capacity to produce and competitive pricing. The applicant is not imparting its technical knowledge and expertise to the Indian company based on which the Indian company will acquire such skills and will be able to make use of it in futu...