https://www.taxtmi.com/caselaws?id=16808 Fees received by a non-resident company for technical services rendered to Indian companies were treated as part of "industrial or commercial profits" under Article III of the India-West Germany Double Taxation Agreement. The exclusion in Article III(3) covered rents, royalties, interest, dividends, management charges, remuneration for labour or personal services, and ship or aircraft income, but did not expressly exclude technical service fees. The terms "management charges" and "remuneration for labour or personal services" were held not to extend to technical services rendered through technical personnel. Because the treaty did not specifically carve out such fees, they remained taxable only as industrial or commercial profits, subject to the treaty conditions. en-us Wed, 11 Mar 1998 00:00:00 +0530 Sat, 12 Sep 2009 13:13:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=16808 Fees received by a non-resident company for technical services rendered to Indian companies were treated as part of "industrial or commercial profits" under Article III of the India-West Germany Double Taxation Agreement. The exclusion in Article III(3) covered rents, royalties, interest, dividends, management charges, remuneration for labour or personal services, and ship or aircraft income, but did not expressly exclude technical service fees. The terms "management charges" and "remuneration for labour or personal services" were held not to extend to technical services rendered through technical personnel. Because the treaty did not specifically carve out such fees, they remained taxable only as industrial or commercial profits, subject to the treaty conditions. Case-Laws Income Tax Wed, 11 Mar 1998 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=16808