Receipts Not Qualify as FTS if No Technology Transfer: Delhi HC Rules Income Not Taxable Under India-UK DTAA

The Delhi High Court has ruled that receipts do not qualify as "Fees for Technical Services" (FTS) if no technology transfer occurs, thus holding the income not taxable under the India-UK DTAA (Double Taxation Avoidance Agreement). The court emphasized that for a service to be classified as FTS under the DTAA, it must "make available" technical knowledge, experience, or skill to the recipient, enabling them to apply the technology independently. Mere rendering of services, even if technical, without such knowledge transfer, does not attract FTS taxation.