The Indian Income Tax Appellate Tribunal (ITAT) issued its decision on 23 January 2013 in the case of Sandvik Australia Pty. Ltd. v. DDIT (ITA No. 93/PN/2011) that the provision of information technology (IT) support services are not regarded as making available technical services/knowledge.
(a) Facts. The Taxpayer (i.e. Sandvik Australia Pty. Ltd.), a company incorporated in Australia, acts as a global IT support centre for the Asia-Pacific region and is responsible for providing the ne…