https://www.taxtmi.com/caselaws?id=119145 Preparation of material safety data sheets does not constitute fees for included services under the Indo-Swiss Tax Treaty unless the service makes available technical knowledge, experience, skill, know-how or processes, or develops and transfers a technical plan or design. Delivery of the sheets alone, without technology transfer enabling future independent use, falls outside that definition and does not require tax deduction at source. Under the Indo-French Treaty protocol, the more favourable rate under the Indo-US Treaty applies to qualifying technical-service remittances for the relevant period without further governmental action, reducing the applicable source-tax rate from 20% to 15%. en-us Fri, 31 Dec 2004 00:00:00 +0530 Tue, 18 Jun 2024 12:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=119145 Preparation of material safety data sheets does not constitute fees for included services under the Indo-Swiss Tax Treaty unless the service makes available technical knowledge, experience, skill, know-how or processes, or develops and transfers a technical plan or design. Delivery of the sheets alone, without technology transfer enabling future independent use, falls outside that definition and does not require tax deduction at source. Under the Indo-French Treaty protocol, the more favourable rate under the Indo-US Treaty applies to qualifying technical-service remittances for the relevant period without further governmental action, reducing the applicable source-tax rate from 20% to 15%. Case-Laws Income Tax Fri, 31 Dec 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=119145