Some Indian tax treaties (for instance, with the United Arab Emirates) do not include provisions for ‘fees for technical services’ (FTS). In such a case, if an item of income amounts to FTS under the Indian Income Tax Act, 1961 (IITA1961), how should it be characterized for the tax treaty purpose? The Indian Income Tax Appellate Tribunal (ITAT) has examined this question in a decision in the case of...