https://www.taxtmi.com/caselaws?id=296821 Consulting fees received for advising, recommending, assisting, conducting training programmes and reviewing healthcare projects were held not to constitute royalty because they were not consideration for the use of copyright, trademark, or industrial, commercial or scientific experience. The receipts also were not fees for included services because no technical knowledge, experience, skill, know-how or process was made available to the Indian recipients. The Tribunal further noted the assessee had no permanent establishment in India and relied on its own earlier orders in the assessee's favour, which had not been reversed. The receipts were therefore treated as not taxable in India as royalty or fees for included services. en-us Wed, 02 May 2018 00:00:00 +0530 Mon, 09 Aug 2021 08:52:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=296821 Consulting fees received for advising, recommending, assisting, conducting training programmes and reviewing healthcare projects were held not to constitute royalty because they were not consideration for the use of copyright, trademark, or industrial, commercial or scientific experience. The receipts also were not fees for included services because no technical knowledge, experience, skill, know-how or process was made available to the Indian recipients. The Tribunal further noted the assessee had no permanent establishment in India and relied on its own earlier orders in the assessee's favour, which had not been reversed. The receipts were therefore treated as not taxable in India as royalty or fees for included services. Case-Laws Income Tax Wed, 02 May 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=296821