https://www.taxtmi.com/caselaws?id=253087 Payments to foreign research entities for pre-clinical and clinical study work were treated as fees for technical services because the agreements showed continuous technical interaction and the making available of technical knowledge, experience, skill, know-how and processes. The fact that information, know-how, processes and intellectual property generated during the studies would vest in the payer reinforced that the services were not limited to a final report. The receipts were therefore not treated as mere business profits and were held taxable in India under the relevant treaty provisions, giving rise to a corresponding obligation to deduct tax at source. Failure to do so attracted liability under sections 201(1) and 201(1A). en-us Wed, 12 Nov 2014 00:00:00 +0530 Fri, 14 Nov 2014 12:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=253087 Payments to foreign research entities for pre-clinical and clinical study work were treated as fees for technical services because the agreements showed continuous technical interaction and the making available of technical knowledge, experience, skill, know-how and processes. The fact that information, know-how, processes and intellectual property generated during the studies would vest in the payer reinforced that the services were not limited to a final report. The receipts were therefore not treated as mere business profits and were held taxable in India under the relevant treaty provisions, giving rise to a corresponding obligation to deduct tax at source. Failure to do so attracted liability under sections 201(1) and 201(1A). Case-Laws Income Tax Wed, 12 Nov 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=253087