https://www.taxtmi.com/caselaws?id=15628 The High Court noted that the Tribunal had rejected the revenue's reference request on the ground that no technical service was rendered in India, but had not addressed section 9(1)(vii)(b) of the Income-tax Act, 1961. That provision deems fees for technical services payable by a resident to accrue or arise in India, subject to the statutory exception. Because the taxability of the payment to the non-resident depended on that legal provision, the controversy raised a question of law fit for reference under section 256(2). The reference application was therefore allowed and the Tribunal was directed to state the case on the questions proposed by the revenue. en-us Fri, 05 Feb 1999 00:00:00 +0530 Wed, 26 Aug 2009 15:11:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=15628 The High Court noted that the Tribunal had rejected the revenue's reference request on the ground that no technical service was rendered in India, but had not addressed section 9(1)(vii)(b) of the Income-tax Act, 1961. That provision deems fees for technical services payable by a resident to accrue or arise in India, subject to the statutory exception. Because the taxability of the payment to the non-resident depended on that legal provision, the controversy raised a question of law fit for reference under section 256(2). The reference application was therefore allowed and the Tribunal was directed to state the case on the questions proposed by the revenue. Case-Laws Income Tax Fri, 05 Feb 1999 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=15628