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Documents citing N.M. Rothschild & Sons Limited , London vs Dcit, Circle Int. Taxation 2(2)(2), New ... on 30 June, 2023

Dcit (International Taxation) ... vs M/S. Mott Macdonald Limited., Mumbai on 31 January, 2025

10. It is noted that identical services as rendered by the assessee was subject matter of consideration before Hon'ble Delhi Tribunal in case of N.M. Rothschild and Sons Ltd. vs. DCIT(supra) Hon'ble Delhi Tribunal after considering the various arguments and decisions observed as under:

Income Tax Appellate Tribunal - Mumbai Cites 22 - Cited by 0 - Full Document

Cochin International Airport ... vs Dcit Corporate Circle 1(1), Cochin on 23 September, 2025

14. Similarly the Hon'ble Delhi Tribunal in ITA No. 517/Del/2022 dated 30/06/2023 in the case of N.M. Rothchild & Sons Ltd. vs. DCIT wherein the Tribunal had held that the advisory services given by the appellant are not in the nature of technical services and is only in the nature of managerial services and also does not satisfy the requirement of "make available" under clause 13 of DTAA with UK and therefore it is not taxable in India.

Income Tax Appellate Tribunal - Cochin Cites 6 - Cited by 0 - Full Document

Cochin International Airport ... vs Dcit Corporate Circle 1(1), Cochin on 23 September, 2025

14. Similarly the Hon'ble Delhi Tribunal in ITA No. 517/Del/2022 dated 30/06/2023 in the case of N.M. Rothchild & Sons Ltd. vs. DCIT wherein the Tribunal had held that the advisory services given by the appellant are not in the nature of technical services and is only in the nature of managerial services and also does not satisfy the requirement of "make available" under clause 13 of DTAA with UK and therefore it is not taxable in India.

Income Tax Appellate Tribunal - Cochin Cites 6 - Cited by 0 - Full Document

Cochin International Airport ... vs Dcit Corporate Circle 1(1), Cochin on 23 September, 2025

14. Similarly the Hon'ble Delhi Tribunal in ITA No. 517/Del/2022 dated 30/06/2023 in the case of N.M. Rothchild & Sons Ltd. vs. DCIT wherein the Tribunal had held that the advisory services given by the appellant are not in the nature of technical services and is only in the nature of managerial services and also does not satisfy the requirement of "make available" under clause 13 of DTAA with UK and therefore it is not taxable in India.

Income Tax Appellate Tribunal - Cochin Cites 6 - Cited by 0 - Full Document

Cochin International Airport ... vs Dcit Corporate Circle 1(1), Cochin on 23 September, 2025

14. Similarly the Hon'ble Delhi Tribunal in ITA No. 517/Del/2022 dated 30/06/2023 in the case of N.M. Rothchild & Sons Ltd. vs. DCIT wherein the Tribunal had held that the advisory services given by the appellant are not in the nature of technical services and is only in the nature of managerial services and also does not satisfy the requirement of "make available" under clause 13 of DTAA with UK and therefore it is not taxable in India.

Income Tax Appellate Tribunal - Cochin Cites 6 - Cited by 0 - Full Document

Cochin International Airport ... vs Dcit Corporate Circle 1(1), Cochin on 23 September, 2025

14. Similarly the Hon'ble Delhi Tribunal in ITA No. 517/Del/2022 dated 30/06/2023 in the case of N.M. Rothchild & Sons Ltd. vs. DCIT wherein the Tribunal had held that the advisory services given by the appellant are not in the nature of technical services and is only in the nature of managerial services and also does not satisfy the requirement of "make available" under clause 13 of DTAA with UK and therefore it is not taxable in India.

Income Tax Appellate Tribunal - Cochin Cites 6 - Cited by 0 - Full Document

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