https://www.taxtmi.com/caselaws?id=200412 Receipts for data, information and advisory support rendered outside India do not constitute fees for technical services under the India-USA tax treaty unless the services make available technical knowledge, skill, know-how or a process capable of independent application by the Indian recipient. Such receipts are instead taxable, if at all, as business profits. Where the non-resident has no permanent establishment in India, the treaty does not permit India to tax those business profits. Earlier mutual agreement procedure resolution and consistent appellate treatment supported the same tax position. 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 data, information and advisory support rendered outside India do not constitute fees for technical services under the India-USA tax treaty unless the services make available technical knowledge, skill, know-how or a process capable of independent application by the Indian recipient. Such receipts are instead taxable, if at all, as business profits. Where the non-resident has no permanent establishment in India, the treaty does not permit India to tax those business profits. Earlier mutual agreement procedure resolution and consistent appellate treatment supported the same tax position. Case-Laws Income Tax Mon, 08 Aug 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=200412