https://www.taxtmi.com/caselaws?id=75526 The payer was held entitled to challenge the tax demand linked to its TDS obligation because the statutory scheme allows objection to the underlying liability, not only by the non-resident recipient. For fees for technical services, taxability under section 9(1)(vii)(c) continued to depend on services being rendered and utilised in India; on the facts, pure offshore technical services were not taxable, but start-up services and overall responsibility performed through Indian supervision were taxable and required TDS. Treaty exemption was denied because the assessee failed to prove that the service fee was inseparably linked to equipment supply. en-us Mon, 16 Mar 2009 00:00:00 +0530 Mon, 17 Nov 2025 15:38:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=75526 The payer was held entitled to challenge the tax demand linked to its TDS obligation because the statutory scheme allows objection to the underlying liability, not only by the non-resident recipient. For fees for technical services, taxability under section 9(1)(vii)(c) continued to depend on services being rendered and utilised in India; on the facts, pure offshore technical services were not taxable, but start-up services and overall responsibility performed through Indian supervision were taxable and required TDS. Treaty exemption was denied because the assessee failed to prove that the service fee was inseparably linked to equipment supply. Case-Laws Income Tax Mon, 16 Mar 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=75526