https://www.taxtmi.com/caselaws?id=239338 Advisory, educational, training and consultancy receipts were held not to constitute royalty or fees for included services because they did not make available technical knowledge, skill or know-how, and any use of the service provider's name was only incidental. In the absence of a permanent establishment, the receipts could not be taxed as business profits. The award-related payment was also held not to be fees for included services, as it was confined to facilitation and academic support without transfer of know-how. Reimbursement of expenses followed the same non-taxable character, and interest under section 234B was found unsustainable on the accepted facts. en-us Fri, 22 Feb 2013 00:00:00 +0530 Thu, 07 Jan 2016 13:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=239338 Advisory, educational, training and consultancy receipts were held not to constitute royalty or fees for included services because they did not make available technical knowledge, skill or know-how, and any use of the service provider's name was only incidental. In the absence of a permanent establishment, the receipts could not be taxed as business profits. The award-related payment was also held not to be fees for included services, as it was confined to facilitation and academic support without transfer of know-how. Reimbursement of expenses followed the same non-taxable character, and interest under section 234B was found unsustainable on the accepted facts. Case-Laws Income Tax Fri, 22 Feb 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=239338