https://www.taxtmi.com/caselaws?id=219679 The Tribunal determined that payments made to non-residents for repairs were classified as business income, not fees for technical services, and were not taxable in India due to the absence of a Permanent Establishment. Section 206AA was deemed inapplicable as the payments were not for technical services. The Tribunal clarified that grossing up for TDS purposes should be done at the rates in force or as per the Double Taxation Avoidance Agreement. The appeals were allowed, stating that the payments were business income not subject to TDS, and partly allowed for the correct method of grossing up under Section 195A. en-us Thu, 11 Oct 2012 00:00:00 +0530 Fri, 21 Dec 2012 11:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=219679 The Tribunal determined that payments made to non-residents for repairs were classified as business income, not fees for technical services, and were not taxable in India due to the absence of a Permanent Establishment. Section 206AA was deemed inapplicable as the payments were not for technical services. The Tribunal clarified that grossing up for TDS purposes should be done at the rates in force or as per the Double Taxation Avoidance Agreement. The appeals were allowed, stating that the payments were business income not subject to TDS, and partly allowed for the correct method of grossing up under Section 195A. Case-Laws Income Tax Thu, 11 Oct 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=219679