https://www.taxtmi.com/caselaws?id=251236 Payments for erection, commissioning, supervision and allied services linked to the import and installation of complex machinery were treated as part of the overall purchase arrangement, not as independent fees for technical services. Because the services were inseparably connected with the sale and successful installation of the machinery, no income was regarded as accruing in India and no tax deduction at source arose. Likewise, payment for designs and drawings used only to support operation and maintenance of the machinery, without independent exploitation or technology transfer, was not taxable in India. On these facts, the non-resident receipts were not subject to withholding tax. en-us Thu, 27 Feb 2014 00:00:00 +0530 Tue, 18 Aug 2015 15:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=251236 Payments for erection, commissioning, supervision and allied services linked to the import and installation of complex machinery were treated as part of the overall purchase arrangement, not as independent fees for technical services. Because the services were inseparably connected with the sale and successful installation of the machinery, no income was regarded as accruing in India and no tax deduction at source arose. Likewise, payment for designs and drawings used only to support operation and maintenance of the machinery, without independent exploitation or technology transfer, was not taxable in India. On these facts, the non-resident receipts were not subject to withholding tax. Case-Laws Income Tax Thu, 27 Feb 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=251236