https://www.taxtmi.com/caselaws?id=277849 The Tribunal held that payments to a non-resident company for certification services were not taxable in India under the India-USA Double Taxation Avoidance Agreement (DTAA) as the company lacked a Permanent Establishment in India. The services were deemed to fall under section 44BB, not fees for technical services. Consequently, the tax deposited by Oil and Natural Gas Corporation Limited (ONGC) was ordered to be refunded, leading to the dismissal of the revenue's appeal. 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 The Tribunal held that payments to a non-resident company for certification services were not taxable in India under the India-USA Double Taxation Avoidance Agreement (DTAA) as the company lacked a Permanent Establishment in India. The services were deemed to fall under section 44BB, not fees for technical services. Consequently, the tax deposited by Oil and Natural Gas Corporation Limited (ONGC) was ordered to be refunded, leading to the dismissal of the revenue's appeal. Case-Laws Income Tax Mon, 16 May 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=277849