https://www.taxtmi.com/caselaws?id=239127 Payments to foreign contract research organisations for bio-equivalence and clinical studies were held not to constitute fees for included services because the service providers did not make available technical knowledge, experience, skill, know-how or processes, nor transfer any technical plan or design. The receipts were treated as business income under Article 7, and since the foreign recipients had no permanent establishment in India, the amounts were not taxable in India. On that basis, no tax was required to be withheld on the remittances, and the Revenue's appeals failed. en-us Fri, 24 May 2013 00:00:00 +0530 Thu, 07 Nov 2013 11:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=239127 Payments to foreign contract research organisations for bio-equivalence and clinical studies were held not to constitute fees for included services because the service providers did not make available technical knowledge, experience, skill, know-how or processes, nor transfer any technical plan or design. The receipts were treated as business income under Article 7, and since the foreign recipients had no permanent establishment in India, the amounts were not taxable in India. On that basis, no tax was required to be withheld on the remittances, and the Revenue's appeals failed. Case-Laws Income Tax Fri, 24 May 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=239127