https://www.taxtmi.com/caselaws?id=287205 A one-time consideration for granting a contractual right to render business process outsourcing services was held not taxable in India as business income under business connection or service PE principles, because no operations were carried on in India and no services were rendered through employees or other personnel in India. The service PE conclusion was found to rest on the wrong transaction and an incorrect reading of the contract, so the addition was deleted. A separate amount for off-the-shelf software and standard support was also held not taxable as royalty or fees for technical services, following prior identical precedent. The substantive additions therefore did not survive. en-us Wed, 07 Aug 2019 00:00:00 +0530 Fri, 03 Apr 2020 13:00:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=287205 A one-time consideration for granting a contractual right to render business process outsourcing services was held not taxable in India as business income under business connection or service PE principles, because no operations were carried on in India and no services were rendered through employees or other personnel in India. The service PE conclusion was found to rest on the wrong transaction and an incorrect reading of the contract, so the addition was deleted. A separate amount for off-the-shelf software and standard support was also held not taxable as royalty or fees for technical services, following prior identical precedent. The substantive additions therefore did not survive. Case-Laws Income Tax Wed, 07 Aug 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=287205