https://www.taxtmi.com/caselaws?id=379233 The High Court upheld the Tribunal's decision, ruling that payments made to Amas Bank for services related to Global Depository Receipts were not subject to tax deduction at source under Section 195 of the Income Tax Act. The services were deemed commercial, performed outside India, and did not qualify as fees for technical services under Section 9(1)(vii). The court emphasized that income must arise from activities connected to India for tax liability, dismissing the Revenue's appeals and affirming that the payments were not taxable in India. en-us Mon, 22 Apr 2019 00:00:00 +0530 Tue, 23 Jul 2019 15:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=379233 The High Court upheld the Tribunal's decision, ruling that payments made to Amas Bank for services related to Global Depository Receipts were not subject to tax deduction at source under Section 195 of the Income Tax Act. The services were deemed commercial, performed outside India, and did not qualify as fees for technical services under Section 9(1)(vii). The court emphasized that income must arise from activities connected to India for tax liability, dismissing the Revenue's appeals and affirming that the payments were not taxable in India. Case-Laws Income Tax Mon, 22 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=379233