ITAT Delhi in the case of ACIT v Petronet LNG Ltd. has ruled that mere rendering of services involving technical knowledge, skill etc. would not be sufficient to classify it as Fees for Technical Services. The ITAT held that such technology would be considered to have been ‘made available’ when the person acquiring the service is able to apply such technology on their own.

Also Read: TPO’s role limited to determining Arm’s Length Price; Not required to comment on commercial wisdom of transaction

Share your thoughts using the comment section below