https://www.taxtmi.com/caselaws?id=293754 Intra-group support, coordination, advisory and back-office services were not taxable in India as fees for technical services under the India-UK DTAA because they did not make available technical knowledge, experience, skill, know-how or processes, nor involve transfer of a technical plan or design. The applicant also had no permanent establishment in India, so the receipts were not taxable as business income. As the underlying payment was not chargeable to tax in India, the statutory trigger for withholding under section 195 did not arise, and no tax deduction at source was required from the Indian payer. en-us Fri, 19 Jul 2019 00:00:00 +0530 Wed, 24 Mar 2021 16:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=293754 Intra-group support, coordination, advisory and back-office services were not taxable in India as fees for technical services under the India-UK DTAA because they did not make available technical knowledge, experience, skill, know-how or processes, nor involve transfer of a technical plan or design. The applicant also had no permanent establishment in India, so the receipts were not taxable as business income. As the underlying payment was not chargeable to tax in India, the statutory trigger for withholding under section 195 did not arise, and no tax deduction at source was required from the Indian payer. Case-Laws Income Tax Fri, 19 Jul 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=293754