https://www.taxtmi.com/caselaws?id=326476 Payments for crane design review and audit services rendered outside India were held not to be royalty or fees for technical services because no technical plan, design, knowledge, skill or know-how was made available, and no Indian permanent establishment was shown; accordingly, no withholding tax obligation arose. The crane supply consideration payable to the Chinese supplier was not partly taxable as embedded service income because the supply and service contracts were separate, the service payments were already taxed, and the installation permanent establishment threshold was not met on the actual presence and activity record. The Indian intermediary was also not an agency permanent establishment because it lacked authority to conclude contracts and was not devoted exclusively to the supplier's business. en-us Wed, 23 Mar 2016 00:00:00 +0530 Mon, 04 Apr 2016 10:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=326476 Payments for crane design review and audit services rendered outside India were held not to be royalty or fees for technical services because no technical plan, design, knowledge, skill or know-how was made available, and no Indian permanent establishment was shown; accordingly, no withholding tax obligation arose. The crane supply consideration payable to the Chinese supplier was not partly taxable as embedded service income because the supply and service contracts were separate, the service payments were already taxed, and the installation permanent establishment threshold was not met on the actual presence and activity record. The Indian intermediary was also not an agency permanent establishment because it lacked authority to conclude contracts and was not devoted exclusively to the supplier's business. Case-Laws Income Tax Wed, 23 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=326476