https://www.taxtmi.com/caselaws?id=214645 ISO 9000 certification receipts were treated as business profits because the activity consisted of audit, inspection, evaluation of quality systems, report preparation and certification, and did not amount to managerial, technical or consultancy services under Article 12 of the Indo-German DTAA. As a result, the income was not fee for technical services and section 44D did not apply. Where the income was subject to tax deduction at source under section 195, the assessee had no advance tax liability, so interest for default in advance tax under section 234B could not be levied. en-us Fri, 06 Jul 2012 00:00:00 +0530 Mon, 03 Aug 2026 17:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=214645 ISO 9000 certification receipts were treated as business profits because the activity consisted of audit, inspection, evaluation of quality systems, report preparation and certification, and did not amount to managerial, technical or consultancy services under Article 12 of the Indo-German DTAA. As a result, the income was not fee for technical services and section 44D did not apply. Where the income was subject to tax deduction at source under section 195, the assessee had no advance tax liability, so interest for default in advance tax under section 234B could not be levied. Case-Laws Income Tax Fri, 06 Jul 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=214645