https://www.taxtmi.com/caselaws?id=77078 Accreditation receipts were held outside the India-Australia treaty charge as royalty or fees for technical services because the assessment and certification activities did not make available technical knowledge, experience, skill, know-how or processes to the recipients. Occasional on-site assessment and witness audit visits, including presence for less than 90 days in a 12-month period, did not create a permanent establishment in India. As the receipts were not taxable on either basis, the payments were not chargeable to tax in India and no withholding obligation arose. en-us Fri, 06 Aug 2010 00:00:00 +0530 Mon, 31 Dec 2012 12:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=77078 Accreditation receipts were held outside the India-Australia treaty charge as royalty or fees for technical services because the assessment and certification activities did not make available technical knowledge, experience, skill, know-how or processes to the recipients. Occasional on-site assessment and witness audit visits, including presence for less than 90 days in a 12-month period, did not create a permanent establishment in India. As the receipts were not taxable on either basis, the payments were not chargeable to tax in India and no withholding obligation arose. Case-Laws Income Tax Fri, 06 Aug 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=77078