https://www.taxtmi.com/caselaws?id=260085 Remittances for liaisoning, business solicitation, documentation support and project coordination were examined on their actual nature, and not their label, to determine whether they amounted to fees for technical services under Explanation 2 to Section 9(1)(vii) of the Income-tax Act. The article states that such activities were not advisory or consultancy services in the legal sense, so the payments fell outside fees for technical services and disallowance under Section 40(a)(i) did not arise. It also explains that the India-UAE tax treaty applied because the recipients were UAE residents with no permanent establishment in India, with the result that the income was taxable only in UAE and no tax was deductible in India. en-us Fri, 29 May 2015 00:00:00 +0530 Wed, 04 May 2016 13:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=260085 Remittances for liaisoning, business solicitation, documentation support and project coordination were examined on their actual nature, and not their label, to determine whether they amounted to fees for technical services under Explanation 2 to Section 9(1)(vii) of the Income-tax Act. The article states that such activities were not advisory or consultancy services in the legal sense, so the payments fell outside fees for technical services and disallowance under Section 40(a)(i) did not arise. It also explains that the India-UAE tax treaty applied because the recipients were UAE residents with no permanent establishment in India, with the result that the income was taxable only in UAE and no tax was deductible in India. Case-Laws Income Tax Fri, 29 May 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=260085