https://www.taxtmi.com/caselaws?id=277849 Payments to a non-resident for third-party certification of oil reserves were treated as not taxable in India where the services were rendered outside India and no technical knowledge, skill, know-how, or experience was made available to the payer. The consideration therefore did not constitute fees for technical services under the Indo-USA DTAA. It could be taxed as business profits only if the non-resident had a permanent establishment in India and the profits were attributable to that establishment. As no permanent establishment existed in India, the receipts were held not taxable in India. en-us Mon, 16 May 2016 00:00:00 +0530 Thu, 27 Dec 2018 06:29:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=277849 Payments to a non-resident for third-party certification of oil reserves were treated as not taxable in India where the services were rendered outside India and no technical knowledge, skill, know-how, or experience was made available to the payer. The consideration therefore did not constitute fees for technical services under the Indo-USA DTAA. It could be taxed as business profits only if the non-resident had a permanent establishment in India and the profits were attributable to that establishment. As no permanent establishment existed in India, the receipts were held not taxable in India. Case-Laws Income Tax Mon, 16 May 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=277849