https://www.taxtmi.com/caselaws?id=65477 Structured technical training of technical and managerial personnel by a non-resident was analysed as fee for technical services because the programme imparted technical knowledge, experience, skill and know-how for use in the assessee's Indian business. On that basis, the payment was treated as falling within section 9(1)(vii) of the Income-tax Act and article 13(4)(c) of the India-UK DTAA, because the training made available technical knowledge and expertise. The fee was therefore deemed to accrue and arise in India, became taxable in India under the treaty framework, and attracted deduction of tax at source under section 195. en-us Fri, 31 Oct 2008 00:00:00 +0530 Tue, 22 Feb 2011 11:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=65477 Structured technical training of technical and managerial personnel by a non-resident was analysed as fee for technical services because the programme imparted technical knowledge, experience, skill and know-how for use in the assessee's Indian business. On that basis, the payment was treated as falling within section 9(1)(vii) of the Income-tax Act and article 13(4)(c) of the India-UK DTAA, because the training made available technical knowledge and expertise. The fee was therefore deemed to accrue and arise in India, became taxable in India under the treaty framework, and attracted deduction of tax at source under section 195. Case-Laws Income Tax Fri, 31 Oct 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=65477