https://www.taxtmi.com/caselaws?id=387506 Reimbursements to non-residents are described as outside withholding where they are mere pass-through expenses and not income chargeable to tax in India. Aircraft charter and related sponsorship or ground-rights payments are distinguished from royalty because they do not involve use of equipment or immovable property in the statutory sense. Consultancy, survey, maintenance, crew support, and security services are analysed under the Act and the relevant DTAAs, with treaty taxation depending on the make available condition; without transfer of usable skill or knowledge, the services are not fees for technical services. Amounts treated as security deposits are presented as non-expenditure and, when returned, do not attract withholding. en-us Thu, 10 Oct 2019 00:00:00 +0530 Thu, 24 Oct 2019 09:34:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=387506 Reimbursements to non-residents are described as outside withholding where they are mere pass-through expenses and not income chargeable to tax in India. Aircraft charter and related sponsorship or ground-rights payments are distinguished from royalty because they do not involve use of equipment or immovable property in the statutory sense. Consultancy, survey, maintenance, crew support, and security services are analysed under the Act and the relevant DTAAs, with treaty taxation depending on the make available condition; without transfer of usable skill or knowledge, the services are not fees for technical services. Amounts treated as security deposits are presented as non-expenditure and, when returned, do not attract withholding. Case-Laws Income Tax Thu, 10 Oct 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=387506