https://www.taxtmi.com/caselaws?id=72030 Payments to a foreign supplier for prototype engines were characterised as consideration for purchase, not fees for technical services, because the contract read as a whole showed a composite supply of engines with documentation, testing and related deliverables. References to technical requirements, intellectual property and copying restrictions were treated as incidental to the supply and not a separate service engagement. Explanation 2 to section 9(1)(vii) was construed narrowly, and the mere fact that the engines embodied design or know-how did not convert the payment into technical fees. As the sum was not taxable as technical services, no tax was deductible under section 195 and section 201 default did not arise. en-us Mon, 31 Mar 2008 00:00:00 +0530 Wed, 12 Jun 2013 15:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=72030 Payments to a foreign supplier for prototype engines were characterised as consideration for purchase, not fees for technical services, because the contract read as a whole showed a composite supply of engines with documentation, testing and related deliverables. References to technical requirements, intellectual property and copying restrictions were treated as incidental to the supply and not a separate service engagement. Explanation 2 to section 9(1)(vii) was construed narrowly, and the mere fact that the engines embodied design or know-how did not convert the payment into technical fees. As the sum was not taxable as technical services, no tax was deductible under section 195 and section 201 default did not arise. Case-Laws Income Tax Mon, 31 Mar 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=72030