https://www.taxtmi.com/caselaws?id=4677 Referral fee for customer introductions was held not taxable in India because it accrued in Singapore and did not arise in India. It was neither business income, nor royalty, nor fees for technical services under the Act or the India-Singapore DTAA, as no technical knowledge, know-how, or intellectual property was made available to the Indian entity. The applicant also had no business connection or permanent establishment in India, so no part of the fee was attributable to India. Since the amount was not chargeable to tax in India, no withholding obligation arose under section 195. en-us Fri, 04 Jul 2008 00:00:00 +0530 Mon, 06 Oct 2008 20:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=4677 Referral fee for customer introductions was held not taxable in India because it accrued in Singapore and did not arise in India. It was neither business income, nor royalty, nor fees for technical services under the Act or the India-Singapore DTAA, as no technical knowledge, know-how, or intellectual property was made available to the Indian entity. The applicant also had no business connection or permanent establishment in India, so no part of the fee was attributable to India. Since the amount was not chargeable to tax in India, no withholding obligation arose under section 195. Case-Laws Income Tax Fri, 04 Jul 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=4677