https://www.taxtmi.com/caselaws?id=398549 Payments to a non-resident for liaison, procurement of orders and incidental reimbursement were treated as commission-related outgoings, not fees for technical, managerial or consultancy services. Although the agreement and invoices used consulting-style descriptions, the actual work was limited to interfacing and order procurement, and the non-resident certified that no technical or managerial services were rendered. On those facts, the sums were not chargeable to tax in India in the absence of a permanent establishment or business connection, so tax deduction at source under section 195 did not arise. The demand under section 201 and interest under section 201(1A) were deleted. en-us Wed, 16 Sep 2020 00:00:00 +0530 Fri, 18 Sep 2020 17:54:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=398549 Payments to a non-resident for liaison, procurement of orders and incidental reimbursement were treated as commission-related outgoings, not fees for technical, managerial or consultancy services. Although the agreement and invoices used consulting-style descriptions, the actual work was limited to interfacing and order procurement, and the non-resident certified that no technical or managerial services were rendered. On those facts, the sums were not chargeable to tax in India in the absence of a permanent establishment or business connection, so tax deduction at source under section 195 did not arise. The demand under section 201 and interest under section 201(1A) were deleted. Case-Laws Income Tax Wed, 16 Sep 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=398549