https://www.taxtmi.com/caselaws?id=346678 Routing a training-service remittance through a foreign holding company did not change its character into a mere reimbursement, because the payment was for services rendered for the assessee's benefit; accordingly, the withholding and disallowance issue could not be avoided on that basis. For legal consultancy fees paid to a foreign law firm, the specific DTAA article for independent personal services prevailed over the general fees for technical services article. As the recipient had no fixed base or requisite stay in India, the income was not taxable in India and no tax was deductible at source, so the related disallowance could not survive. The additions for both remittances were deleted. en-us Wed, 12 Apr 2017 00:00:00 +0530 Mon, 21 Aug 2017 19:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=346678 Routing a training-service remittance through a foreign holding company did not change its character into a mere reimbursement, because the payment was for services rendered for the assessee's benefit; accordingly, the withholding and disallowance issue could not be avoided on that basis. For legal consultancy fees paid to a foreign law firm, the specific DTAA article for independent personal services prevailed over the general fees for technical services article. As the recipient had no fixed base or requisite stay in India, the income was not taxable in India and no tax was deductible at source, so the related disallowance could not survive. The additions for both remittances were deleted. Case-Laws Income Tax Wed, 12 Apr 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=346678