(International Taxation) v. Bio-Rad Laboratories (Singapore) Pte. Ltd.

Bombardier Inc., Quebec, Canada vs. Assistant Commissioner of Income Tax, Circle 1(1)(2), Delhi

In the result, the appeal of the Assessee are allowed

Bench: Shri M. Balaganesh & Shri Vimal Kumarbombardier Inc, Vs. Acit, 400, Dorval, Cote-Vertu, Circle-1(1)(2), Road West, Quebee Delhi Canada-H4S1Y9 (Appellant) (Respondent) Pan: Aaccb7177J Assessee By : Shri Sriram Seshadri, Cas Shri Varun Jain, Ca Shri Mohit Agarwal, Ca Ms. Amulya K. Ca Revenue By: Shri M. S. Nethrapal, Cit Dr Date Of Hearing 15/09/2025 Date Of Pronouncement 10/12/2025

…a recent decision in Commissioner of Income-tax, International Taxation v. RELX Inc [2024] 160 taxmann.com 109/470 ITR 611 had concurred with the view of this court in CIT v. Bio-Rad Laborataries (Singapore) Pte. Ltd. [2023] 155 taxmann.com 646/296 Taxman 167/459 ITR 5 (Delhi) and observed as under: 15. Similarly, in order for that income to fall within the ambit of "fees for included services", it was imperative for the Department to establish that the assessee was rendering technical or consultancy services and which included making available technical knowledge, experience, skill, know- how or processes. As ha…

Gsma Ltd, Usa vs. ACIT Circle Intl Taxation 1(3)(1), New Delhi

In the result, appeal of the assessee is allowed

Bench: Shri Vikas Awasthy& Shri Brajesh Kumar Singhआअसं.2446/िद"ी/2024(िन.व. 2017-18) Gsma Ltd., 1000 Abernathy Road, Suite 450, Atalanta, Untied State Of America ...... अपीलाथ"/Appellant Pan: Aaecg-1610-K बनाम Vs. Assistant Commissioner Of Income-Tax, International Taxation 1(3)(1), Civic Centre, ....."ितवादी/Respondent Minto Road, New Delhi 110002 अपीलाथ" "ारा/ Appellant By: Shri P.P Singh, Advocate "ितवादी"ारा/Respondent By: Shri M.S Nethrapal, Cit-Dr सुनवाई क" ितिथ/ Date Of Hearing : 06/08/2025 घोषणा क" ितिथ/ Date Of Pronouncement : 04/11/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Dated 06.04.2021 Passed U/S. 143(3) R.W.S 144C(13) Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’), For Assessment Year 2017-18. 2. The Registry Has Issued Defect Memo Stating That The Appeal Is Time Barred By 1076 Days. The Assessee Has Filed An Application Supported By An Affidavit Citing Reasons For Delay In Filing Of Appeal.

…आयकर अपीलीय अिधकरण िद"ी पीठ “डी”, िद"ी "ी िवकास अव"थी, "ाियक सद" एवं "ी "जेश कुमार िसंह, लेखाकार सद" के सम" IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “D”, DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER& SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER आअसं.2446/िद"ी/2024(िन.व. 2017-18) GSMA Ltd., 1000 Abernathy Road, Suite 450, Atalanta, Untied State of America ...... अपीलाथ"/Appellant PAN: AAECG-1610-K बनाम Vs. Assistant Commissioner of Income-Tax, International Taxation 1(3)(1), Civic Centre, ....."ितवादी/Respondent Minto Road, New Delhi 110002 अपीलाथ" "ारा/ Appellant by: Shri P.P Singh, Advocate "ितवादी"…

Invesco Holding Company (Us) Inc., Usa vs. Assistant Commissioner of Income Tax, Circle International Taxation 2(1)(1), Delhi

In the result, appeal of the assessee is partly allowed in the terms aforesaid

Bench: Shri Vikas Awasthy& Shri Brajesh Kumar Singhआअसं.846/िद"ी/2025(िन.व. 2022-23) Inveso Holding Company (Us) Inc., C/O Invesco (India) P. Ltd., 15Th Floor, Block 6, North Tower, Divyasree Orion Sez, Raidurgam, Serilingampally, Hyderabad, Telangana 5000032 ...... अपीलाथ"/Appellant Pan: Aaeci-9027-N बनाम Vs. Assisnat Commissioner Of Income-Tax, International Taxation 2(1)(1), Civic Centre, ....."ितवादी/Respondent Minto Road, New Delhi 110002 अपीलाथ" "ारा/ Appellant By: S/Shri Ankul Goyal & Advitya Grover, Advocates "ितवादी"ारा/Respondent By: Shri M.S Nethrapal, Cit-Dr सुनवाई क" ितिथ/ Date Of Hearing : 04/08/2025 घोषणा क" ितिथ/ Date Of Pronouncement : 31/10/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against Assessment Order Dated 20.12.2024 Passed U/S. 143(3) R.W.S 144C(13) Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’), For Assessment Year 2022-23. 2. Shri Ankul Goyal, Appearing On Behalf Of The Assessee Submits That The Solitary Issue In Present Appeal Is Against The Addition Of Rs.54,85,23,539/- In Respect Of Reimbursement Of Cost For Providing It/Support Services Treated As Fee

…आयकर अपीलीय अिधकरण िद"ी पीठ “डी”, िद"ी "ी िवकास अव"थी, "ाियक सद" एवं "ी "जेश कुमार िसंह, लेखाकार सद" के सम" IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “D”, DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER& SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER आअसं.846/िद"ी/2025(िन.व. 2022-23) Inveso Holding Company (US) Inc., C/o Invesco (india) P. Ltd., 15th Floor, Block 6, North Tower, Divyasree Orion SEZ, Raidurgam, Serilingampally, Hyderabad, Telangana 5000032 ...... अपीलाथ"/Appellant PAN: AAECI-9027-N बनाम Vs. Assisnat Commissioner of Income-Tax, International Taxation 2(1)(1), Civic Centre, ....."ितवादी/Respo…

Pratt & Whitney Canada Corp., Canada vs. Deputy Commissioner of Income Tax, International Taxation, Circle 2(2)(2), New Delhi

In the result, assessee’s appeals in ITA No

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘D’ BENCH, NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No. 665/DEL/2025 [A.Y 2018-19] ITA No. 666/DEL/2025 [A.Y 2022-23] M/s Pratt & Whitney Canada Corp. Vs. The Dy. C.I.T [resulted out of amalgamation of Pratt & Circle – 2(2)(2) Whitney Canada Corp and Turbo Engines Corp International Taxation 1000, Boul Marie Victorin, Longueuil New Delhi Quebec –J4G1A1 PAN – AAPCP 1595 F ITA No. 620/DEL/2025 [A.Y 2018-19] ITA No. 626/DEL/2025 [A.Y 2022-23] M/s Pratt & Whitney Canada (Sea) Pte Ltd Vs. The Dy. C.I.T 10, Loyang…

Pratt & Whitney Canada Corp., Canada vs. Deputy Commissioner of Income Tax, International Taxation, Circle 2(2)(2), New Delhi

In the result, assessee’s appeals in ITA No

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘D’ BENCH, NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No. 665/DEL/2025 [A.Y 2018-19] ITA No. 666/DEL/2025 [A.Y 2022-23] M/s Pratt & Whitney Canada Corp. Vs. The Dy. C.I.T [resulted out of amalgamation of Pratt & Circle – 2(2)(2) Whitney Canada Corp and Turbo Engines Corp International Taxation 1000, Boul Marie Victorin, Longueuil New Delhi Quebec –J4G1A1 PAN – AAPCP 1595 F ITA No. 620/DEL/2025 [A.Y 2018-19] ITA No. 626/DEL/2025 [A.Y 2022-23] M/s Pratt & Whitney Canada (Sea) Pte Ltd Vs. The Dy. C.I.T 10, Loyang…

Pratt & Whitney Canada (Sea) Pte. Ltd., Singapore vs. Deputy Commissioner of Income Tax, International Taxation, Circle 2(2)(2), New Delhi

In the result, assessee’s appeals in ITA No

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘D’ BENCH, NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No. 665/DEL/2025 [A.Y 2018-19] ITA No. 666/DEL/2025 [A.Y 2022-23] M/s Pratt & Whitney Canada Corp. Vs. The Dy. C.I.T [resulted out of amalgamation of Pratt & Circle – 2(2)(2) Whitney Canada Corp and Turbo Engines Corp International Taxation 1000, Boul Marie Victorin, Longueuil New Delhi Quebec –J4G1A1 PAN – AAPCP 1595 F ITA No. 620/DEL/2025 [A.Y 2018-19] ITA No. 626/DEL/2025 [A.Y 2022-23] M/s Pratt & Whitney Canada (Sea) Pte Ltd Vs. The Dy. C.I.T 10, Loyang…

Pratt & Whitney Canada (Sea) Pte. Ltd., Singapore vs. Deputy Commissioner of Income Tax, International Taxation, Circle 2(2)(2), New Delhi

In the result, assessee’s appeals in ITA No

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘D’ BENCH, NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No. 665/DEL/2025 [A.Y 2018-19] ITA No. 666/DEL/2025 [A.Y 2022-23] M/s Pratt & Whitney Canada Corp. Vs. The Dy. C.I.T [resulted out of amalgamation of Pratt & Circle – 2(2)(2) Whitney Canada Corp and Turbo Engines Corp International Taxation 1000, Boul Marie Victorin, Longueuil New Delhi Quebec –J4G1A1 PAN – AAPCP 1595 F ITA No. 620/DEL/2025 [A.Y 2018-19] ITA No. 626/DEL/2025 [A.Y 2022-23] M/s Pratt & Whitney Canada (Sea) Pte Ltd Vs. The Dy. C.I.T 10, Loyang…

ACIT, Spl. Range-9, New Delhi vs. Timex Group India Ltd., New Delhi

In the result, the appeal of the assessee is partly allowed

Bench: Shri Vimal Kumar & Shri Brajesh Kumar Singh

…01.06.2022 in ITA No. 7017-7020/2019 (Para 11). (Upheld by Delhi HC in ITA No. 444/2022 vide Order dt. 11.11.2022 against which SLP pending in SLP No. 24397/2024, notice not issued) 3. Delhi HC in CIT(IT) v. Bio Rad Laboratories (Singapore) Pte. Ltd., [2023] 459 ITR 5 (Del.) (Para 4) held dismissed Revenue's appeal where long term service contract was in play between the Indian and the foreign company and Revenue took the plea of fulfilment of "make available" clause. 4. ITAT Delhi in Invesco Holding Company (US) Inc. v. ACIT in ITA No. 784 & 785 of 2023, Order dt. 23.07.2024 (Para 7-8) held that reimbursement I…

Timex Group India Ltd., New Delhi vs. Addi. CIT Spl.Range-9, New Delhi

In the result, the appeal of the assessee is partly allowed

Bench: Shri Vimal Kumar & Shri Brajesh Kumar Singh[Assessment Year: 2013-14] M/S Timex Group India Ltd. Additional Commissioner Of Income 106-107, Ambadeep Building, Tax, Special Range-9, Kasturba Gandhi Marg, Vs New Delhi-110002 New Delhi-110001 Pan-Aaact0773C Assessee Revenue [Assessment Year: 2013-14] Additional Commissioner Of M/S Timex Group India Ltd. Income Tax, Special Range-9, 106-107, Ambadeep Building, New Delhi-110002 Vs Kasturba Gandhi Marg, New Delhi-110001 Pan-Aaact0773C Revenue Assessee Assessee By Shri Tushar Jarwal, Adv. Shri Aayush Nagpal, Adv. & Shri Vikrant Maheshwari, Adv. Revenue By Shri Rohit Garg, Cit-Dr Date Of Hearing 01.07.2025 Date Of Pronouncement 26.09.2025

…01.06.2022 in ITA No. 7017-7020/2019 (Para 11). (Upheld by Delhi HC in ITA No. 444/2022 vide Order dt. 11.11.2022 against which SLP pending in SLP No. 24397/2024, notice not issued) 3. Delhi HC in CIT(IT) v. Bio Rad Laboratories (Singapore) Pte. Ltd., [2023] 459 ITR 5 (Del.) (Para 4) held dismissed Revenue's appeal where long term service contract was in play between the Indian and the foreign company and Revenue took the plea of fulfilment of "make available" clause. 4. ITAT Delhi in Invesco Holding Company (US) Inc. v. ACIT in ITA No. 784 & 785 of 2023, Order dt. 23.07.2024 (Para 7-8) held that reimbursement I…

Keller Asiapacific Limited, Singapore vs. The Assistant Commissioner of Income Tax, Circle International Taxation

In the result, appeal of the assessee is partly allowed in the terms

Bench: Shri Vikas Awasthy & Shri Naveen Chandraआअसं.3540/दिल्ली/2023 (नि.व. 2021-22)

…rovision of Information Technology and other Administrative Services to its affiliate in India were not in the nature of FTS under India-US DTAA. The said decision of the Tribunal was upheld by the Hon'ble Delhi High Court in appeal by the Revenue reported as 459 ITR 5 (Del). 9. In the case of Criteo Singapore Pte. Ltd. vs. ACIT, 170 taxmann.com 162 (Delhi-Trib.) the coordinate Bench while dealing with a similar situation after referring to catena of judgments and Article 12(4) of India-Singapore DTAA held as under:- “56. In the instant case, we find that the receipts in question are for rendering the services ca…

M/S. Ceva Freight Llc, New Delhi vs. DDIT, New Delhi

In the result, the appeal of the assessee in ITA No

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

…ITA No. 1264/DEL/2014 [A.Y. 2010-11] CEVA Freight LLC Vs. The Dy. D.I.T IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘D’ BENCH, NEW DELHI BEFORE MS. MADHUMITA ROY, JUDICIAL MEMBER, AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No. 1264/DEL/2014 [A.Y. 2010-11] CEVA Freight LLC Vs. The Dy. D.I.T 15350, Vickery Drive Circle – 1(1) Houston, Texas 77032 USA International Taxation ***** New Delhi KPMG, DLF Building No. 10 8th Floor, Tower B, DLF Cyber City Phase – 2, Gurgaon. PAN – AAHCM 2797 C (Applicant) (Respondent) Assessee By : Shri Salil Kapoor, Adv Shri Anil Chachra, Adv Department By : Shri Vizay B. Va…

Tungsten Automation England Limited (Formerly Known As Tungsten Network Limited) vs. Deputy Commissioner of Income Tax, International Taxation, Circle 3(1)(1), New Delhi

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE TEJAS KARIA

…a-Singapore DTAA, the services would have to satisfy the 'make available' test and such services should enable the person acquiring the services to apply the technology contained therein. 18. As mentioned elsewhere, the agreement is effective 6 (2023) 459 ITR 5 Digitally Signed By:GANGA SINGH RAWAT Signing Date:14.07.2025 18:41:49 Signature Not Verified ITA 92/2025 and ITA 93/2025 Page 29 of 49 from 01.01.2010 and we are in Assessment Years 2018- 19 and 2019-120 [sic...20]. In our considered o…

Tungsten Automation England Limited (Formerly Known As Tungsten Network Limited) vs. Deputy Commissioner of Income Tax, International Taxation, Circle 3(1)(1) New Delhi

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE TEJAS KARIA

…a-Singapore DTAA, the services would have to satisfy the 'make available' test and such services should enable the person acquiring the services to apply the technology contained therein. 18. As mentioned elsewhere, the agreement is effective 6 (2023) 459 ITR 5 Digitally Signed By:GANGA SINGH RAWAT Signing Date:14.07.2025 18:41:49 Signature Not Verified ITA 92/2025 and ITA 93/2025 Page 29 of 49 from 01.01.2010 and we are in Assessment Years 2018- 19 and 2019-120 [sic...20]. In our considered o…

Pr. Commissioner of Income Tax, International Taxation-1, New Delhi vs. Goodrich Corporation

Accordingly dismissed. Pending applications are also dismissed

Bench: The Learned Itat Assailing The Order Dated 05.01.2024 Passed By The Assessing Officer [Ao] Under Section 147 Read With Section 144C(13) Of The Act. 3. The Assessee Is A Company, Which Is Tax Resident Of The United States Of America [Usa]. The Assessee Has Also Furnished A Tax Residency Certificate [Trc] From The Concerned Authorities Of The Said Country. Digitally Signed By:Tarun Rana Signing Date:01.06.2025 13:30:53 Signature Not Verified

…ing Date:01.06.2025 13:30:53 Signature Not Verified ITA 173/2025 Page 11 of 14 15. This court in a recent decision in CIT v. Relx Inc.: (2024) 470 ITR 611 had concurred with the view of this court in CIT v. Bio-Rad Laborataries (Singapore) Pte. Ltd.: (2023) 459 ITR 5 and observed as under: 15. Similarly, in order for that income to fall within the ambit of “fees for included services”, it was imperative for the Department to establish that the assessee was rendering technical or consultancy services and which included making available technical knowledge, experience, skill, know-how or processes. As has been fo…

Pr. Commissioner of Income Tax, International Taxation-1, New Delhi vs. Goodrich Corporation

Accordingly dismissed. Pending applications are also dismissed

Bench: The Learned Itat Assailing The Order Dated 05.01.2024 Passed By The Assessing Officer [Ao] Under Section 147 Read With Section 144C(13) Of The Act. 3. The Assessee Is A Company, Which Is Tax Resident Of The United States Of America [Usa]. The Assessee Has Also Furnished A Tax Residency Certificate [Trc] From The Concerned Authorities Of The Said Country. Digitally Signed By:Tarun Rana Signing Date:01.06.2025 13:30:53 Signature Not Verified

…ing Date:01.06.2025 13:30:53 Signature Not Verified ITA 173/2025 Page 11 of 14 15. This court in a recent decision in CIT v. Relx Inc.: (2024) 470 ITR 611 had concurred with the view of this court in CIT v. Bio-Rad Laborataries (Singapore) Pte. Ltd.: (2023) 459 ITR 5 and observed as under: 15. Similarly, in order for that income to fall within the ambit of “fees for included services”, it was imperative for the Department to establish that the assessee was rendering technical or consultancy services and which included making available technical knowledge, experience, skill, know-how or processes. As has been fo…

Anand Singh, Village Shahpur Turk vs. Income Tax Officer 69(5), Delhi

In the result, the appeal of the Assessee are allowed

Bench: Shri M. Balaganesh & Shri Vimal Kumarbombardier Inc, Vs. Acit, 400, Dorval, Cote-Vertu, Circle-1(1)(2), Road West, Quebee Delhi Canada-H4S1Y9 (Appellant) (Respondent) Pan: Aaccb7177J Assessee By : Shri Sriram Seshadri, Cas Shri Varun Jain, Ca Shri Mohit Agarwal, Ca Ms. Amulya K. Ca Revenue By: Shri M. S. Nethrapal, Cit Dr Date Of Hearing 15/09/2025 Date Of Pronouncement 10/12/2025

…a recent decision in Commissioner of Income-tax, International Taxation v. RELX Inc [2024] 160 taxmann.com 109/470 ITR 611 had concurred with the view of this court in CIT v. Bio-Rad Laborataries (Singapore) Pte. Ltd. [2023] 155 taxmann.com 646/296 Taxman 167/459 ITR 5 (Delhi) and observed as under: 15. Similarly, in order for that income to fall within the ambit of "fees for included services", it was imperative for the Department to establish that the assessee was rendering technical or consultancy services and which included making available technical knowledge, experience, skill, know- how or processes. As ha…

DCIT, New Delhi vs. M/S. Rhc Holding Pvt. Ltd., New Delhi

In the result, appeal of the assessee is allowed

Bench: Shri Vikas Awasthy& Shri Brajesh Kumar Singhआअसं.2446/िद"ी/2024(िन.व. 2017-18) Gsma Ltd., 1000 Abernathy Road, Suite 450, Atalanta, Untied State Of America ...... अपीलाथ"/Appellant Pan: Aaecg-1610-K बनाम Vs. Assistant Commissioner Of Income-Tax, International Taxation 1(3)(1), Civic Centre, ....."ितवादी/Respondent Minto Road, New Delhi 110002 अपीलाथ" "ारा/ Appellant By: Shri P.P Singh, Advocate "ितवादी"ारा/Respondent By: Shri M.S Nethrapal, Cit-Dr सुनवाई क" ितिथ/ Date Of Hearing : 06/08/2025 घोषणा क" ितिथ/ Date Of Pronouncement : 04/11/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Dated 06.04.2021 Passed U/S. 143(3) R.W.S 144C(13) Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’), For Assessment Year 2017-18. 2. The Registry Has Issued Defect Memo Stating That The Appeal Is Time Barred By 1076 Days. The Assessee Has Filed An Application Supported By An Affidavit Citing Reasons For Delay In Filing Of Appeal.

…आयकर अपीलीय अिधकरण िद"ी पीठ “डी”, िद"ी "ी िवकास अव"थी, "ाियक सद" एवं "ी "जेश कुमार िसंह, लेखाकार सद" के सम" IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “D”, DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER& SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER आअसं.2446/िद"ी/2024(िन.व. 2017-18) GSMA Ltd., 1000 Abernathy Road, Suite 450, Atalanta, Untied State of America ...... अपीलाथ"/Appellant PAN: AAECG-1610-K बनाम Vs. Assistant Commissioner of Income-Tax, International Taxation 1(3)(1), Civic Centre, ....."ितवादी/Respondent Minto Road, New Delhi 110002 अपीलाथ" "ारा/ Appellant by: Shri P.P Singh, Advocate "ितवादी"…

Commissioner of Income Tax International Tax- 1 New Delhi vs. M/S Expeditors International of Washington Inc

Bench: HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR,HON'BLE MR. JUSTICE YASHWANT VARMA

…services that impart lasting technical benefits are classifiable as fees for technical services. It was on a consideration of the aforesaid that this court in Bio-Rad [CIT (International Taxation) v. Bio-Rad Laboratories (Singapore) Pte. Ltd., (2023) 459 ITR 5 (Delhi); 2023 SCC OnLine Del 6770.] had held that the real test would be the transfer of technical knowledge, the knowledge and skills and expertise of the provider being absorbed by the payer and who would then have the capability to deploy that knowledge or skill without reference to the original provider. This reinforces our view that the m…