https://www.taxtmi.com/caselaws?id=210465 Specialised General Business Support Services covering finance, taxation, legal, IT, procurement and marketing support were treated as consultancy services because they involved specialised expertise and "made available" technical knowledge that the recipient could independently apply after the arrangement ended. The payments were therefore fees for technical services under Article 13.4(c) of the India-UK Tax Treaty and constituted income in the hands of the non-resident provider. The same payments were not royalty under section 9(1)(vi) of the Income-tax Act or Article 13, because no right to use intellectual property or know-how was granted. As the receipts were taxable in India, withholding under section 195 applied despite the absence of a permanent establishment. en-us Tue, 17 Jan 2012 00:00:00 +0530 Sat, 21 Apr 2012 16:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=210465 Specialised General Business Support Services covering finance, taxation, legal, IT, procurement and marketing support were treated as consultancy services because they involved specialised expertise and "made available" technical knowledge that the recipient could independently apply after the arrangement ended. The payments were therefore fees for technical services under Article 13.4(c) of the India-UK Tax Treaty and constituted income in the hands of the non-resident provider. The same payments were not royalty under section 9(1)(vi) of the Income-tax Act or Article 13, because no right to use intellectual property or know-how was granted. As the receipts were taxable in India, withholding under section 195 applied despite the absence of a permanent establishment. Case-Laws Income Tax Tue, 17 Jan 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=210465