https://www.taxtmi.com/caselaws?id=17524 The HC held that no NOC would be granted: the purported "business connection" between the Indian company and the non-resident consultant was not established, but the success fee payable to the non-resident constituted fees for technical/consultancy services within section 9(1)(vii)(b) and was therefore deemed to accrue or arise in India. Accordingly the success fee is chargeable to tax under the Act and the petitioners are not entitled to a no objection certificate. en-us Fri, 02 May 1997 00:00:00 +0530 Mon, 13 Oct 2025 15:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=17524 The HC held that no NOC would be granted: the purported "business connection" between the Indian company and the non-resident consultant was not established, but the success fee payable to the non-resident constituted fees for technical/consultancy services within section 9(1)(vii)(b) and was therefore deemed to accrue or arise in India. Accordingly the success fee is chargeable to tax under the Act and the petitioners are not entitled to a no objection certificate. Case-Laws Income Tax Fri, 02 May 1997 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=17524