https://www.taxtmi.com/caselaws?id=206282 Routine data-processing services, including sorting, reviewing, scanning, batching and transmitting data, were analysed as non-technical support work rather than managerial, technical or consultancy services. Under Article 13 of the India-UK DTAA and section 9(1)(vii), fees for technical services arise only where technical knowledge, experience, skill, know-how or processes are made available to the recipient; on these facts, no such making available occurred, so the consideration was not taxable as technical services income. Because the payment was not chargeable to tax in India, the withholding obligation under section 195 also did not arise. en-us Mon, 16 May 2011 00:00:00 +0530 Tue, 18 Dec 2012 16:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=206282 Routine data-processing services, including sorting, reviewing, scanning, batching and transmitting data, were analysed as non-technical support work rather than managerial, technical or consultancy services. Under Article 13 of the India-UK DTAA and section 9(1)(vii), fees for technical services arise only where technical knowledge, experience, skill, know-how or processes are made available to the recipient; on these facts, no such making available occurred, so the consideration was not taxable as technical services income. Because the payment was not chargeable to tax in India, the withholding obligation under section 195 also did not arise. Case-Laws Income Tax Mon, 16 May 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=206282