https://www.taxtmi.com/caselaws?id=75827 Referral fees for merely connecting clients and candidates were not taxable in India as royalty or fees for technical services because the activity did not involve any transfer of technical knowledge, experience, skill, know-how or processes, and the treaty "make available" test was not satisfied. The receipts also were not taxable as business profits under the India-UK treaty because no permanent establishment existed in India; the stated Indian address was only a virtual office and did not amount to a fixed place of business or dependent agent arrangement. Accordingly, no tax was required to be withheld under section 195. en-us Fri, 05 Mar 2010 00:00:00 +0530 Wed, 30 Jan 2013 19:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=75827 Referral fees for merely connecting clients and candidates were not taxable in India as royalty or fees for technical services because the activity did not involve any transfer of technical knowledge, experience, skill, know-how or processes, and the treaty "make available" test was not satisfied. The receipts also were not taxable as business profits under the India-UK treaty because no permanent establishment existed in India; the stated Indian address was only a virtual office and did not amount to a fixed place of business or dependent agent arrangement. Accordingly, no tax was required to be withheld under section 195. Case-Laws Income Tax Fri, 05 Mar 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=75827