IT/ILT : After the amendment of Indo-UK DTAA effective from 11 February, 1994 managerial services are not covered in the definition of FTS and even the technical or consultancy services, if they do not meet the criteria of 'make available', cannot be treated as FTS. Services generally related to human resource matters, cost control, fund management, quality and design reviews etc are routine managerial activities and cannot be classified as technical or consultancy services. Providing
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