https://www.taxtmi.com/caselaws?id=381706 Referral commission paid to a non-resident foreign concern for introducing clients and performing services outside India was not taxable in India. The payment did not accrue or arise in India, was not deemed income under section 9 because no operations were carried out in India, and was neither interest, royalty nor fees for technical services. It also did not qualify as fees for included services under the India-USA DTAA, as no technical knowledge or skill was made available. No tax was therefore deductible under section 195, and disallowance under section 40(a)(i) was not sustainable. en-us Wed, 12 Jun 2019 00:00:00 +0530 Mon, 17 Jun 2019 11:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=381706 Referral commission paid to a non-resident foreign concern for introducing clients and performing services outside India was not taxable in India. The payment did not accrue or arise in India, was not deemed income under section 9 because no operations were carried out in India, and was neither interest, royalty nor fees for technical services. It also did not qualify as fees for included services under the India-USA DTAA, as no technical knowledge or skill was made available. No tax was therefore deductible under section 195, and disallowance under section 40(a)(i) was not sustainable. Case-Laws Income Tax Wed, 12 Jun 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=381706