https://www.taxtmi.com/caselaws?id=274550 Amounts payable to foreign group entities did not accrue as income in India where remittance was contingent on RBI approval, so additions based on accrual were deleted. The Tribunal also held that the relevant tax treaties taxed royalties and fees for technical services on a receipt or payment basis; because the amounts were not actually paid during the year, they were not taxable in India as fees for technical services for that year. The assessee succeeded on these substantive taxability issues, and the remaining grounds were disposed of as not pressed. en-us Fri, 21 Dec 2012 00:00:00 +0530 Tue, 21 Aug 2018 15:37:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=274550 Amounts payable to foreign group entities did not accrue as income in India where remittance was contingent on RBI approval, so additions based on accrual were deleted. The Tribunal also held that the relevant tax treaties taxed royalties and fees for technical services on a receipt or payment basis; because the amounts were not actually paid during the year, they were not taxable in India as fees for technical services for that year. The assessee succeeded on these substantive taxability issues, and the remaining grounds were disposed of as not pressed. Case-Laws Income Tax Fri, 21 Dec 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=274550