https://www.taxtmi.com/caselaws?id=25997 Technical fees received by a non-resident for furnishing information from outside India did not accrue or arise in India merely because the information was used in India or because some connection existed with the Indian payer. Applying the binding Supreme Court position, the court held that no relevant activity or operation was carried on by the foreign company in India, so there was no taxable business connection on these facts. The engineering fees likewise could not be treated as income accruing in India on the Revenue's basis, and no part of those fees was liable to Indian tax. The questions were answered in favour of the assessee and against the Revenue. en-us Mon, 14 Feb 1983 00:00:00 +0530 Tue, 02 Feb 2010 11:48:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=25997 Technical fees received by a non-resident for furnishing information from outside India did not accrue or arise in India merely because the information was used in India or because some connection existed with the Indian payer. Applying the binding Supreme Court position, the court held that no relevant activity or operation was carried on by the foreign company in India, so there was no taxable business connection on these facts. The engineering fees likewise could not be treated as income accruing in India on the Revenue's basis, and no part of those fees was liable to Indian tax. The questions were answered in favour of the assessee and against the Revenue. Case-Laws Income Tax Mon, 14 Feb 1983 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=25997