https://www.taxtmi.com/caselaws?id=334712 Legal fees paid to non-resident attorneys for work on a proposed foreign acquisition were treated as outside the section 9(1)(vi) and 9(1)(vii) deeming provisions because the services were used to evaluate and progress an overseas business opportunity and to earn income from a source outside India; an existing foreign source of income was not required. Under the India-UK treaty, the specific provision on independent professional services prevailed over the general article on royalties and fees for technical services, and the absence of a permanent establishment or business presence in India meant the fees were not taxable in India. As a result, no tax was deductible at source. en-us Thu, 25 Aug 2016 00:00:00 +0530 Sat, 19 Nov 2016 11:55:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=334712 Legal fees paid to non-resident attorneys for work on a proposed foreign acquisition were treated as outside the section 9(1)(vi) and 9(1)(vii) deeming provisions because the services were used to evaluate and progress an overseas business opportunity and to earn income from a source outside India; an existing foreign source of income was not required. Under the India-UK treaty, the specific provision on independent professional services prevailed over the general article on royalties and fees for technical services, and the absence of a permanent establishment or business presence in India meant the fees were not taxable in India. As a result, no tax was deductible at source. Case-Laws Income Tax Thu, 25 Aug 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=334712