https://www.taxtmi.com/caselaws?id=296842 Consideration received under a Master Service Agreement was treated as non-taxable in India because the Tribunal followed its earlier rulings that identical advisory and consulting receipts were neither royalty nor fees for technical services. The services did not make available any technical knowledge, skill or process, so they did not satisfy the treaty requirements for fees for technical services. The Tribunal further held that the receipts were business profits and, in the absence of a permanent establishment in India, could not be taxed in India. en-us Fri, 30 Nov 2018 00:00:00 +0530 Mon, 09 Aug 2021 09:55:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=296842 Consideration received under a Master Service Agreement was treated as non-taxable in India because the Tribunal followed its earlier rulings that identical advisory and consulting receipts were neither royalty nor fees for technical services. The services did not make available any technical knowledge, skill or process, so they did not satisfy the treaty requirements for fees for technical services. The Tribunal further held that the receipts were business profits and, in the absence of a permanent establishment in India, could not be taxed in India. Case-Laws Income Tax Fri, 30 Nov 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=296842