https://www.taxtmi.com/caselaws?id=184283 Payments to non-residents for conference speaking and clinical research testing were held not to be fees for included services under the India-US treaty because the services did not make available technical knowledge, experience, skill, know-how, or processes to the payer. The management expert merely shared business experience and strategy at a conference, and the clinical research organisations applied their own expertise to generate reports without transferring reusable know-how. As the treaty test was not met, no tax withholding obligation arose under section 195, and the related demand under sections 201 and 201(1A) could not stand. en-us Thu, 01 Jul 2010 00:00:00 +0530 Wed, 16 Aug 2023 17:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=184283 Payments to non-residents for conference speaking and clinical research testing were held not to be fees for included services under the India-US treaty because the services did not make available technical knowledge, experience, skill, know-how, or processes to the payer. The management expert merely shared business experience and strategy at a conference, and the clinical research organisations applied their own expertise to generate reports without transferring reusable know-how. As the treaty test was not met, no tax withholding obligation arose under section 195, and the related demand under sections 201 and 201(1A) could not stand. Case-Laws Income Tax Thu, 01 Jul 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=184283