Advisory Services Receipts Not Taxed as Technical Knowledge under India-UK DTAA: ITAT

N.M. Rothchild & Sons Ltd. Vs DCIT (ITAT Delhi)

Conclusion: In present facts of the case, it was held that the services rendered were in the nature of advisory services as per the terms of the agreement, therefore these services cannot be the part of Fees for Technical Services (FTS) under Article 13 of India – UK DTAA.  Further, in the assessment orders, the Assessing Officer himself has stated that some of the services are of the nature of FTS. Thus, the Assessing Officer clearly admits that

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