https://www.taxtmi.com/caselaws?id=200412 Receipts for services rendered outside India were analysed under the India-USA tax treaty and characterised as not constituting fees for technical services because the payer did not receive any technical knowledge, skill, know-how, or process that could be independently applied. The article applies the treaty's "make available" requirement and notes that the same treatment had been accepted in earlier years through mutual agreement procedure and prior appellate decisions. It further states that, absent a permanent establishment in India, the receipts could not be taxed as business profits in India. en-us Mon, 08 Aug 2016 00:00:00 +0530 Wed, 28 Mar 2018 08:07:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=200412 Receipts for services rendered outside India were analysed under the India-USA tax treaty and characterised as not constituting fees for technical services because the payer did not receive any technical knowledge, skill, know-how, or process that could be independently applied. The article applies the treaty's "make available" requirement and notes that the same treatment had been accepted in earlier years through mutual agreement procedure and prior appellate decisions. It further states that, absent a permanent establishment in India, the receipts could not be taxed as business profits in India. Case-Laws Income Tax Mon, 08 Aug 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=200412