https://www.taxtmi.com/caselaws?id=261515 Design review and quality control services rendered by a Finnish non-resident were not fees for technical services under the India-Finland DTAA because they did not make available technical knowledge, skill, know-how or processes to the recipient, nor did they involve development and transfer of a technical plan or design. As no permanent establishment in India was shown, the receipts were not taxable as business profits either. On that basis, the payments were not chargeable to tax in India and section 195 did not require deduction of tax at source. en-us Wed, 08 Jul 2015 00:00:00 +0530 Mon, 09 Nov 2015 10:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=261515 Design review and quality control services rendered by a Finnish non-resident were not fees for technical services under the India-Finland DTAA because they did not make available technical knowledge, skill, know-how or processes to the recipient, nor did they involve development and transfer of a technical plan or design. As no permanent establishment in India was shown, the receipts were not taxable as business profits either. On that basis, the payments were not chargeable to tax in India and section 195 did not require deduction of tax at source. Case-Laws Income Tax Wed, 08 Jul 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=261515