https://www.taxtmi.com/caselaws?id=271000 The court ruled that the supply management service fees received by Cummins Limited, UK, do not qualify as "Fees for Technical Services" or "royalties" under the India-UK Double Tax Avoidance Agreement. As a result, the fees are not taxable in India as there is no Permanent Establishment, and CTIL is not obligated to withhold tax under Section 195 of the Income-tax Act. en-us Tue, 12 Jan 2016 00:00:00 +0530 Tue, 03 May 2016 11:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=271000 The court ruled that the supply management service fees received by Cummins Limited, UK, do not qualify as "Fees for Technical Services" or "royalties" under the India-UK Double Tax Avoidance Agreement. As a result, the fees are not taxable in India as there is no Permanent Establishment, and CTIL is not obligated to withhold tax under Section 195 of the Income-tax Act. Case-Laws Income Tax Tue, 12 Jan 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=271000