https://www.taxtmi.com/caselaws?id=120914 A remittance of credit rating fees to a non-resident was held not chargeable to tax in India as fees for included services under the India-USA DTAA because the service did not make available technical knowledge, experience, skill, know-how, or a technical plan or design to the payer. The credit rating exercise produced commercial information, but no technical expertise was transferred that would enable the payer to apply the technology independently. As the payment was not taxable in India under article 12, no obligation arose to deduct tax at source under section 195 of the Income-tax Act, 1961. en-us Tue, 09 Oct 2007 00:00:00 +0530 Wed, 10 Jan 2024 15:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=120914 A remittance of credit rating fees to a non-resident was held not chargeable to tax in India as fees for included services under the India-USA DTAA because the service did not make available technical knowledge, experience, skill, know-how, or a technical plan or design to the payer. The credit rating exercise produced commercial information, but no technical expertise was transferred that would enable the payer to apply the technology independently. As the payment was not taxable in India under article 12, no obligation arose to deduct tax at source under section 195 of the Income-tax Act, 1961. Case-Laws Income Tax Tue, 09 Oct 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=120914