https://www.taxtmi.com/caselaws?id=122377 Composite cross-border payments for value added services may be split between treaty-covered royalty or fees for technical services and independent business receipts where the service bundle contains both kinds of elements. The text explains that some components, such as use of commercial experience and equipment, can fall within royalty/technical service treatment, while operational elements like continuity of supply, consistency checks, key account management and similar support functions may remain business services. In the absence of a demonstrated permanent establishment in India, a fact-based apportionment of the payment was treated as reasonable and consistent with the India-UK treaty analysis. en-us Mon, 05 Apr 2010 00:00:00 +0530 Mon, 13 Aug 2012 13:01:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=122377 Composite cross-border payments for value added services may be split between treaty-covered royalty or fees for technical services and independent business receipts where the service bundle contains both kinds of elements. The text explains that some components, such as use of commercial experience and equipment, can fall within royalty/technical service treatment, while operational elements like continuity of supply, consistency checks, key account management and similar support functions may remain business services. In the absence of a demonstrated permanent establishment in India, a fact-based apportionment of the payment was treated as reasonable and consistent with the India-UK treaty analysis. Case-Laws Income Tax Mon, 05 Apr 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=122377