https://www.taxtmi.com/caselaws?id=400231 Receipts for intermediary services such as marketing, sales support, project management and customer support are taxable as fees for technical services under the India-Sweden treaty only if the services make available technical knowledge, skill or know-how so that the recipient can apply it independently later; on the stated facts, that requirement was not met. Offshore supply income is not attributable to an Indian permanent establishment where the supplies are separately structured, manufactured and sold outside India, payment is received outside India, and no territorial business presence for those supplies is established in India. en-us Thu, 29 Oct 2020 00:00:00 +0530 Tue, 05 Nov 2024 11:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=400231 Receipts for intermediary services such as marketing, sales support, project management and customer support are taxable as fees for technical services under the India-Sweden treaty only if the services make available technical knowledge, skill or know-how so that the recipient can apply it independently later; on the stated facts, that requirement was not met. Offshore supply income is not attributable to an Indian permanent establishment where the supplies are separately structured, manufactured and sold outside India, payment is received outside India, and no territorial business presence for those supplies is established in India. Case-Laws Income Tax Thu, 29 Oct 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=400231