https://www.taxtmi.com/caselaws?id=401112 Receipts characterised as fees for technical services under section 9(1)(vii) still required treaty-level examination under Article 12 of the applicable DTAA. For Sandvik Asia Private Limited, the services and factual matrix were unchanged from earlier years, and the treaty position had already been accepted in the assessee's favour; the receipts were therefore not taxable in India under Article 12. For Walter Tools India Private Limited, Seco Tools India Private Limited and Dormer Tools India Private Limited, the record was insufficient to establish the true nature of the services, so the matter was restored for fresh factual determination. en-us Wed, 25 Nov 2020 00:00:00 +0530 Thu, 26 Nov 2020 17:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=401112 Receipts characterised as fees for technical services under section 9(1)(vii) still required treaty-level examination under Article 12 of the applicable DTAA. For Sandvik Asia Private Limited, the services and factual matrix were unchanged from earlier years, and the treaty position had already been accepted in the assessee's favour; the receipts were therefore not taxable in India under Article 12. For Walter Tools India Private Limited, Seco Tools India Private Limited and Dormer Tools India Private Limited, the record was insufficient to establish the true nature of the services, so the matter was restored for fresh factual determination. Case-Laws Income Tax Wed, 25 Nov 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=401112