https://www.taxtmi.com/caselaws?id=279214 Payments for foreign training, examination and certification were not finally determined to be fees for technical services because the record did not conclusively show the trainers' stay in India or satisfaction of the make available test, so the matter was remitted for fresh verification and the assessee could prove that the trainers stayed less than 90 days. By contrast, amounts paid to the Indian service provider were treated as contractual sharing of income or profit on a principal-to-principal basis, not commission for services rendered on another's behalf, so section 194H did not apply and the related disallowance was deleted. en-us Tue, 29 May 2018 00:00:00 +0530 Fri, 08 Mar 2019 06:55:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=279214 Payments for foreign training, examination and certification were not finally determined to be fees for technical services because the record did not conclusively show the trainers' stay in India or satisfaction of the make available test, so the matter was remitted for fresh verification and the assessee could prove that the trainers stayed less than 90 days. By contrast, amounts paid to the Indian service provider were treated as contractual sharing of income or profit on a principal-to-principal basis, not commission for services rendered on another's behalf, so section 194H did not apply and the related disallowance was deleted. Case-Laws Income Tax Tue, 29 May 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=279214