https://www.taxtmi.com/caselaws?id=207852 Back-office financial and business support services rendered by the non-resident did not make available technical knowledge, skill, experience, know-how, or process to the payer, so the consideration was not fees for technical services under Article 12 of the India-Netherlands tax treaty. Because the receipts were treated as business income and no permanent establishment in India was shown, the amount was not chargeable to tax in India. As the payment was not taxable in India, the payer had no obligation to deduct tax at source under section 195. The ruling left the royalty issue open. en-us Wed, 21 Dec 2011 00:00:00 +0530 Wed, 12 Dec 2012 18:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=207852 Back-office financial and business support services rendered by the non-resident did not make available technical knowledge, skill, experience, know-how, or process to the payer, so the consideration was not fees for technical services under Article 12 of the India-Netherlands tax treaty. Because the receipts were treated as business income and no permanent establishment in India was shown, the amount was not chargeable to tax in India. As the payment was not taxable in India, the payer had no obligation to deduct tax at source under section 195. The ruling left the royalty issue open. Case-Laws Income Tax Wed, 21 Dec 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=207852