https://www.taxtmi.com/caselaws?id=214164 Under the India-UK treaty, marketing and management service receipts were not fees for technical services unless the services made technical knowledge, skill, experience or processes available so the recipient could perform them independently; only the India-linked services were attributable to the service permanent establishment as business profits. Reimbursement of lease line charges was not royalty because no equipment was placed at the payer's disposal and no technical information was imparted. Interest under sections 234B and 234C was not chargeable where tax was deductible at source on the non-resident's income. Reimbursement for employees' foreign visits required factual verification. Consideration for assignment of customer contracts executed outside India was not taxable in India or attributable to the permanent establishment. en-us Wed, 29 Feb 2012 00:00:00 +0530 Thu, 21 Jun 2012 10:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=214164 Under the India-UK treaty, marketing and management service receipts were not fees for technical services unless the services made technical knowledge, skill, experience or processes available so the recipient could perform them independently; only the India-linked services were attributable to the service permanent establishment as business profits. Reimbursement of lease line charges was not royalty because no equipment was placed at the payer's disposal and no technical information was imparted. Interest under sections 234B and 234C was not chargeable where tax was deductible at source on the non-resident's income. Reimbursement for employees' foreign visits required factual verification. Consideration for assignment of customer contracts executed outside India was not taxable in India or attributable to the permanent establishment. Case-Laws Income Tax Wed, 29 Feb 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=214164