Information Technology Services Income not taxable under article 12 of India- Sweden tax treaty

SCA Hygiene Products AB (Essity Hygiene And Health AB) Vs DCIT (ITAT Mumbai) In order to decide whether or not the services rendered by the assessee fit the definition of ‘fees for technical services’, as applicable under the Indo Swedish tax treaty, the question that we must ask ourselves is not only whether the technical services are performed on the facts of this case, but whether ‘the technical knowledge or skills of the provider should be imparted to and absorbed by the receiver so that the receiver can deploy similar technology or techniques in the future without depend...