https://www.taxtmi.com/caselaws?id=258843 Fees paid to a Moroccan law firm for anti-counterfeiting litigation services were treated as professional legal services under Article 14 of the India-Morocco DTAA, not fees for technical services. Because the firm had no fixed base or permanent establishment in India, the income was taxable only in Morocco as the State of residence. The treaty position prevailed over the domestic charging provisions, so no obligation to deduct tax at source arose and disallowance under section 40(a)(i) was not sustainable. en-us Tue, 06 Jan 2015 00:00:00 +0530 Wed, 22 Apr 2015 07:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=258843 Fees paid to a Moroccan law firm for anti-counterfeiting litigation services were treated as professional legal services under Article 14 of the India-Morocco DTAA, not fees for technical services. Because the firm had no fixed base or permanent establishment in India, the income was taxable only in Morocco as the State of residence. The treaty position prevailed over the domestic charging provisions, so no obligation to deduct tax at source arose and disallowance under section 40(a)(i) was not sustainable. Case-Laws Income Tax Tue, 06 Jan 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=258843