https://www.taxtmi.com/caselaws?id=369295 Line production services rendered in South Africa were held to be administrative and logistical services, not managerial, technical, or consultancy services, because they involved coordination, facilitation, and production support rather than control, technical skill, or advice. The consideration was therefore outside fees for technical services under the Income-tax Act and the India-South Africa treaty. The arrangement was also treated as a services contract, not a grant of any right to use copyright, so the payment did not fall within royalty under domestic law or Article 12. The receipt was not taxable in India on either ground, and the line production addition was deleted. en-us Wed, 03 Oct 2018 00:00:00 +0530 Thu, 15 Nov 2018 11:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=369295 Line production services rendered in South Africa were held to be administrative and logistical services, not managerial, technical, or consultancy services, because they involved coordination, facilitation, and production support rather than control, technical skill, or advice. The consideration was therefore outside fees for technical services under the Income-tax Act and the India-South Africa treaty. The arrangement was also treated as a services contract, not a grant of any right to use copyright, so the payment did not fall within royalty under domestic law or Article 12. The receipt was not taxable in India on either ground, and the line production addition was deleted. Case-Laws Income Tax Wed, 03 Oct 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=369295