https://www.taxtmi.com/caselaws?id=178002 Referral fees paid by an Indian broker for introducing overseas clients were held not taxable in India. The Tribunal found that the income did not accrue or arise in India under the source and business connection provisions because the mere act of referral abroad did not create a real and intimate business connection in India. It also held that the activity was neither managerial, technical nor consultancy in nature, and no technical expertise or know-how was made available, so the receipts did not constitute fees for technical services under section 9(1)(vii). The addition was therefore deleted. en-us Fri, 18 Jan 2013 00:00:00 +0530 Thu, 05 Feb 2026 16:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=178002 Referral fees paid by an Indian broker for introducing overseas clients were held not taxable in India. The Tribunal found that the income did not accrue or arise in India under the source and business connection provisions because the mere act of referral abroad did not create a real and intimate business connection in India. It also held that the activity was neither managerial, technical nor consultancy in nature, and no technical expertise or know-how was made available, so the receipts did not constitute fees for technical services under section 9(1)(vii). The addition was therefore deleted. Case-Laws Income Tax Fri, 18 Jan 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=178002