https://www.taxtmi.com/caselaws?id=245662 Payments to non-resident subcontractors for outsourced animation production work were not treated as fees for technical services in India where the recipients had no permanent establishment or business connection in India and the work formed part of overseas project execution. The statutory exception in section 9(1)(vii)(b) applied because the services were utilised in a business carried on outside India and for earning income from foreign sources. On that basis, no tax deduction at source arose, and the alternative India-China DTAA point was only academic. en-us Fri, 28 Mar 2014 00:00:00 +0530 Fri, 04 Apr 2014 12:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=245662 Payments to non-resident subcontractors for outsourced animation production work were not treated as fees for technical services in India where the recipients had no permanent establishment or business connection in India and the work formed part of overseas project execution. The statutory exception in section 9(1)(vii)(b) applied because the services were utilised in a business carried on outside India and for earning income from foreign sources. On that basis, no tax deduction at source arose, and the alternative India-China DTAA point was only academic. Case-Laws Income Tax Fri, 28 Mar 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=245662