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Technology duly ‘make available’ if experts deputed for ensuring due adherence to assessee’s standards: ITAT

March 11, 2020[2020] 115 taxmann.com 129 (Mumbai - Trib.)

INTERNATIONAL TAXATION : Where, assessee, a US based company, engaged in business of providing management and consulting services, entered into 'Management Provision Agreement' (MPA) with an Indian company namely 'GMIL' which was carrying on business of manufacture, assembly, marketing, and sale of motor vehicles in India, in view of fact that in terms of said agreement, assessee sent its employees in India having technical expertise, who were not only managing affairs but also ensuring due adherence to standards of assessee, by continuously monitoring and mentoring production of GMIL, it could be concluded that they made available technical knowledge and expertise to GMIL and, thus, amount paid to assessee for rendering said services was chargeable to tax in India as 'fee for technical services'

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