https://www.taxtmi.com/caselaws?id=415334 Treaty relief under the India-Poland DTAA was allowed for payments to a fiscally transparent Polish law firm because the partners, not the firm itself, were the taxable persons in Poland, and the receipts were not treated as fees for technical services; the remittance was therefore held not taxable in India. Interest on refund of tax deducted at source paid under protest was also held admissible in line with the Supreme Court principle on refund interest. Payments to a US vendor were not finally characterised as royalty or fees for technical services and were remanded for fresh examination under the later Supreme Court ruling. en-us Mon, 11 Oct 2021 00:00:00 +0530 Fri, 03 Dec 2021 09:19:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=415334 Treaty relief under the India-Poland DTAA was allowed for payments to a fiscally transparent Polish law firm because the partners, not the firm itself, were the taxable persons in Poland, and the receipts were not treated as fees for technical services; the remittance was therefore held not taxable in India. Interest on refund of tax deducted at source paid under protest was also held admissible in line with the Supreme Court principle on refund interest. Payments to a US vendor were not finally characterised as royalty or fees for technical services and were remanded for fresh examination under the later Supreme Court ruling. Case-Laws Income Tax Mon, 11 Oct 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=415334