Sharing of management experience and business strategies by a foreign professional cannot be termed as technical service under India-USA tax treaty

Facts

ISSUE NO. I

• The assessee was an Indian company engaged in the business of manufacturing pharmaceuticals. It paid USD 80,000 to a non-resident named C.K. Prahlad Inc. (“CKP Inc.) of USA without withholding any tax at source thereon. CKP Inc. of USA was a company incorporated under laws of the USA. CKP Inc. had sent one of its professionals (

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