https://www.taxtmi.com/caselaws?id=213253 Payments for airborne geophysical survey, data collection, processing, maps and reports were treated as technical services under domestic law, but they were not taxable under the India-Netherlands treaty because the provider's technical knowledge, skill or know-how was not made available to the recipient for independent future use. The receipt of survey outputs, data and reports alone was insufficient, so the treaty fees for technical services condition was not met. The same payments also were not for the development and transfer of a technical plan or technical design, because the materials supplied were only collected and processed data, photographs, maps and reports, not a technical plan or design. Tax deduction was therefore not required on these payments. en-us Thu, 15 Mar 2012 00:00:00 +0530 Thu, 21 May 2026 17:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=213253 Payments for airborne geophysical survey, data collection, processing, maps and reports were treated as technical services under domestic law, but they were not taxable under the India-Netherlands treaty because the provider's technical knowledge, skill or know-how was not made available to the recipient for independent future use. The receipt of survey outputs, data and reports alone was insufficient, so the treaty fees for technical services condition was not met. The same payments also were not for the development and transfer of a technical plan or technical design, because the materials supplied were only collected and processed data, photographs, maps and reports, not a technical plan or design. Tax deduction was therefore not required on these payments. Case-Laws Income Tax Thu, 15 Mar 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=213253