https://www.taxtmi.com/caselaws?id=71001 Technical know-how fees paid to an Austrian company for services rendered in Austria were not subject to tax deduction at source before remittance because the recipient had no permanent establishment in India. On those facts, the applicable India-Austria Double Taxation Agreement allocated taxing rights outside India, so the remittance did not give rise to Indian tax liability. The Assessing Officer therefore had no basis to require deduction under section 195(2) and should have granted the no-objection for remittance without withholding tax. en-us Fri, 13 Dec 1996 00:00:00 +0530 Wed, 20 Apr 2011 16:58:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=71001 Technical know-how fees paid to an Austrian company for services rendered in Austria were not subject to tax deduction at source before remittance because the recipient had no permanent establishment in India. On those facts, the applicable India-Austria Double Taxation Agreement allocated taxing rights outside India, so the remittance did not give rise to Indian tax liability. The Assessing Officer therefore had no basis to require deduction under section 195(2) and should have granted the no-objection for remittance without withholding tax. Case-Laws Income Tax Fri, 13 Dec 1996 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=71001