https://www.taxtmi.com/caselaws?id=337700 Payments to a foreign group company for IT support were treated as reimbursements for group-level services and cost allocations, not royalty under the Income-tax Act or the India-Canada DTAA, because the payer acquired no right to use equipment, copyright, or other protected software rights; accordingly, no withholding obligation arose under section 195. Payments for management support and advisory services were not fees for included services because the services did not make available technical knowledge, skill, know-how, or processes to the recipient, so they were not chargeable to tax in India and no tax deduction at source was required. The appellate order deleting the withholding demand was sustained. en-us Tue, 03 Jan 2017 00:00:00 +0530 Sat, 14 Jan 2017 07:23:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=337700 Payments to a foreign group company for IT support were treated as reimbursements for group-level services and cost allocations, not royalty under the Income-tax Act or the India-Canada DTAA, because the payer acquired no right to use equipment, copyright, or other protected software rights; accordingly, no withholding obligation arose under section 195. Payments for management support and advisory services were not fees for included services because the services did not make available technical knowledge, skill, know-how, or processes to the recipient, so they were not chargeable to tax in India and no tax deduction at source was required. The appellate order deleting the withholding demand was sustained. Case-Laws Income Tax Tue, 03 Jan 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=337700