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        Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.

        Provisions expressly mentioned in the judgment/order text.

        <h1>Cross-border payments and TDS: permanent establishment and business-connection determine taxability and withholding obligations.</h1> Three advance-ruling summaries address cross-border payment characterisation and TDS: payments to a non-resident for leased circuits were not taxable absent a permanent establishment and were not royalty under the treaty; referral fees from an Indian subsidiary to its foreign parent were not taxable due to absence of business connection so no TDS; consideration for transfer of trade-mark rights is taxable in India, and an independent valuation may be accepted if verified.

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