https://www.taxtmi.com/caselaws?id=284793 Payments to a foreign associated entity for software licences, IT support, lease line charges, training and expatriate salary reimbursement were examined against the royalty and fees for technical services tests. Software payments for a copyrighted article were not treated as royalty because no copyright was acquired. IT support, internet and lease line charges were treated as neither royalty nor technical services, and lease line charges were at most reimbursement. Web-based training did not make available technical knowledge or know-how, and the expatriate salary reimbursement under the secondment arrangement did not create a separate TDS obligation. No tax was deductible, so no default under sections 201(1) and 201(1A) arose. en-us Thu, 01 Aug 2019 00:00:00 +0530 Tue, 10 Dec 2019 20:22:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=284793 Payments to a foreign associated entity for software licences, IT support, lease line charges, training and expatriate salary reimbursement were examined against the royalty and fees for technical services tests. Software payments for a copyrighted article were not treated as royalty because no copyright was acquired. IT support, internet and lease line charges were treated as neither royalty nor technical services, and lease line charges were at most reimbursement. Web-based training did not make available technical knowledge or know-how, and the expatriate salary reimbursement under the secondment arrangement did not create a separate TDS obligation. No tax was deductible, so no default under sections 201(1) and 201(1A) arose. Case-Laws Income Tax Thu, 01 Aug 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=284793