https://www.taxtmi.com/caselaws?id=117496 Annual surveillance fee paid for credit rating services to a non-resident was treated as taxable in India under the India-Australia treaty because the service supplied commercially usable information for resource mobilisation and investor reliance, bringing it within Article 12(3)(c), with ancillary consultancy elements also falling within Article 12(3)(d). The assessee's argument that the payment was outside section 9(1)(vii) was rejected, and the remittance was held subject to withholding tax under section 195 of the Income-tax Act, 1961. en-us Fri, 10 Jun 2005 00:00:00 +0530 Sat, 23 Jun 2012 10:53:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=117496 Annual surveillance fee paid for credit rating services to a non-resident was treated as taxable in India under the India-Australia treaty because the service supplied commercially usable information for resource mobilisation and investor reliance, bringing it within Article 12(3)(c), with ancillary consultancy elements also falling within Article 12(3)(d). The assessee's argument that the payment was outside section 9(1)(vii) was rejected, and the remittance was held subject to withholding tax under section 195 of the Income-tax Act, 1961. Case-Laws Income Tax Fri, 10 Jun 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=117496