https://www.taxtmi.com/caselaws?id=243070 Remittance for clinical trial-related services was characterised as payment for procurement and onward transmission of commercial information, with the recipient acting only as a conduit to its principal. The services did not confer technical know-how on the assessee and did not make available technical knowledge, experience or skill, so the payment was not royalty under section 9(1)(vi) of the Income-tax Act or the India-Sri Lanka DTAA. In the absence of royalty or fees for technical services character, and since the service provider had no permanent establishment in India, the business profits were not taxable in India and tax was not required to be deducted at source under section 195. en-us Fri, 26 Jul 2013 00:00:00 +0530 Sat, 25 Jan 2014 18:17:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=243070 Remittance for clinical trial-related services was characterised as payment for procurement and onward transmission of commercial information, with the recipient acting only as a conduit to its principal. The services did not confer technical know-how on the assessee and did not make available technical knowledge, experience or skill, so the payment was not royalty under section 9(1)(vi) of the Income-tax Act or the India-Sri Lanka DTAA. In the absence of royalty or fees for technical services character, and since the service provider had no permanent establishment in India, the business profits were not taxable in India and tax was not required to be deducted at source under section 195. Case-Laws Income Tax Fri, 26 Jul 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=243070