https://www.taxtmi.com/caselaws?id=395458 Payment to a non-resident UK entity for insurance product development and related advisory support was treated as consultancy services within the scope of "fees for technical or consultancy services". The payer failed to show that the statutory exception in section 9(1)(vii)(b) applied, because an existing business or profession outside India was not established on the facts. The treaty exclusion under Article 13 was also held inapplicable on the material before the Court. The payment was therefore taxable in India and subject to tax deduction at source, and the challenge to the order was rejected. en-us Tue, 19 May 2020 00:00:00 +0530 Mon, 31 Aug 2020 16:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=395458 Payment to a non-resident UK entity for insurance product development and related advisory support was treated as consultancy services within the scope of "fees for technical or consultancy services". The payer failed to show that the statutory exception in section 9(1)(vii)(b) applied, because an existing business or profession outside India was not established on the facts. The treaty exclusion under Article 13 was also held inapplicable on the material before the Court. The payment was therefore taxable in India and subject to tax deduction at source, and the challenge to the order was rejected. Case-Laws Income Tax Tue, 19 May 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=395458