https://www.taxtmi.com/caselaws?id=117622 Foreign lead-manager payments in a GDR issue were treated as taxable in India where the management and selling functions constituted technical services under section 9(1)(vii), making tax deduction at source applicable and supporting liability under sections 201(1) and 201(1A). Underwriting commission was treated differently to the extent it related to underwriting outside the USA, and reimbursement of expenses was held not taxable in India. Payments covered by the India-U.K. treaty were also outside the definition of fees for technical services under Article 13.4(c), so no withholding was required on those treaty-protected sums. The limitation objection to the section 201 order failed because no specific limitation period applied on the facts stated. en-us Fri, 18 Feb 2005 00:00:00 +0530 Thu, 06 Jun 2024 14:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=117622 Foreign lead-manager payments in a GDR issue were treated as taxable in India where the management and selling functions constituted technical services under section 9(1)(vii), making tax deduction at source applicable and supporting liability under sections 201(1) and 201(1A). Underwriting commission was treated differently to the extent it related to underwriting outside the USA, and reimbursement of expenses was held not taxable in India. Payments covered by the India-U.K. treaty were also outside the definition of fees for technical services under Article 13.4(c), so no withholding was required on those treaty-protected sums. The limitation objection to the section 201 order failed because no specific limitation period applied on the facts stated. Case-Laws Income Tax Fri, 18 Feb 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=117622