https://www.taxtmi.com/caselaws?id=280294 Payment to a UAE entity for acting as sole book-runner, global coordinator and lead manager for a GDR issue was treated as commercial services rendered wholly outside India. Because the services were neither rendered nor utilised in India and the recipient had no permanent establishment in India, the amount did not qualify as fees for technical services under section 9(1)(vii)(b) of the Income-tax Act, 1961. The treaty also did not tax the receipt in the absence of a relevant taxing article and any permanent establishment. The payment was therefore not taxable in India and no tax was deductible under section 195. en-us Wed, 26 Apr 2017 00:00:00 +0530 Tue, 30 Apr 2019 06:04:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=280294 Payment to a UAE entity for acting as sole book-runner, global coordinator and lead manager for a GDR issue was treated as commercial services rendered wholly outside India. Because the services were neither rendered nor utilised in India and the recipient had no permanent establishment in India, the amount did not qualify as fees for technical services under section 9(1)(vii)(b) of the Income-tax Act, 1961. The treaty also did not tax the receipt in the absence of a relevant taxing article and any permanent establishment. The payment was therefore not taxable in India and no tax was deductible under section 195. Case-Laws Income Tax Wed, 26 Apr 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=280294