https://www.taxtmi.com/caselaws?id=265211 Certification and audit receipts were examined as a whole and held not to constitute fees for technical services because the assessee did not provide technical, managerial or consultancy advice. The Tribunal's factual finding, based on the nature of the work and the material on record, was not shown to be perverse or vitiated by error of law. As the receipts did not fall within section 9(1)(vii) of the Income-tax Act or Article 12(4) of the Indo-German DTAA, the consequential provisions governing deduction and taxation of such fees did not apply, and the revenue's challenge failed. en-us Mon, 20 Apr 2015 00:00:00 +0530 Thu, 08 Oct 2015 07:28:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=265211 Certification and audit receipts were examined as a whole and held not to constitute fees for technical services because the assessee did not provide technical, managerial or consultancy advice. The Tribunal's factual finding, based on the nature of the work and the material on record, was not shown to be perverse or vitiated by error of law. As the receipts did not fall within section 9(1)(vii) of the Income-tax Act or Article 12(4) of the Indo-German DTAA, the consequential provisions governing deduction and taxation of such fees did not apply, and the revenue's challenge failed. Case-Laws Income Tax Mon, 20 Apr 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=265211