https://www.taxtmi.com/caselaws?id=260085 Remittances for liaisoning, business solicitation, documentation assistance, coordination with authorities and project facilitation are distinguished from genuine advisory or consultancy services for purposes of fees for technical services. The analysis treats consultancy services narrowly under the deeming provision and focuses on the actual services rather than contractual labels or accounting treatment. Where UAE recipients have no permanent establishment in India, Article 14 of the India-UAE tax treaty may allocate the relevant income to the UAE; Article 22 is also identified as placing taxability in the State of residence. Consequently, no Indian tax deduction at source or related disallowance arises. 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 assistance, coordination with authorities and project facilitation are distinguished from genuine advisory or consultancy services for purposes of fees for technical services. The analysis treats consultancy services narrowly under the deeming provision and focuses on the actual services rather than contractual labels or accounting treatment. Where UAE recipients have no permanent establishment in India, Article 14 of the India-UAE tax treaty may allocate the relevant income to the UAE; Article 22 is also identified as placing taxability in the State of residence. Consequently, no Indian tax deduction at source or related disallowance arises. Case-Laws Income Tax Fri, 29 May 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=260085