https://www.taxtmi.com/caselaws?id=123009 Activation charges paid to enable additional functions already embedded in hardware supplied by a foreign vendor were treated as part of the composite sale consideration, not as separate fees for technical services. Because the features were standard and already inbuilt, and no independent technical service element was shown, the payment also did not constitute royalty. On that basis, the assessee had no tax deduction at source obligation on the payment under the applicable income-tax and treaty provisions. en-us Fri, 20 Aug 2010 00:00:00 +0530 Tue, 28 Aug 2012 12:07:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=123009 Activation charges paid to enable additional functions already embedded in hardware supplied by a foreign vendor were treated as part of the composite sale consideration, not as separate fees for technical services. Because the features were standard and already inbuilt, and no independent technical service element was shown, the payment also did not constitute royalty. On that basis, the assessee had no tax deduction at source obligation on the payment under the applicable income-tax and treaty provisions. Case-Laws Income Tax Fri, 20 Aug 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=123009