https://www.taxtmi.com/caselaws?id=181313 Payment for corporate credit rating to a non-resident was treated as consideration for specialised professional services, not for the supply of scientific, technical, industrial or commercial knowledge or information. It therefore did not fall within the royalty article of the India-Australia DTAA. As the recipient had no permanent establishment in India, the income was not chargeable to tax in India under the business profits article either, and the payer had no withholding obligation under section 195. The assessee was accordingly held not liable to deduct tax at source, and the contrary orders were set aside. en-us Mon, 28 Feb 2005 00:00:00 +0530 Wed, 13 Apr 2016 11:34:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=181313 Payment for corporate credit rating to a non-resident was treated as consideration for specialised professional services, not for the supply of scientific, technical, industrial or commercial knowledge or information. It therefore did not fall within the royalty article of the India-Australia DTAA. As the recipient had no permanent establishment in India, the income was not chargeable to tax in India under the business profits article either, and the payer had no withholding obligation under section 195. The assessee was accordingly held not liable to deduct tax at source, and the contrary orders were set aside. Case-Laws Income Tax Mon, 28 Feb 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=181313