https://www.taxtmi.com/caselaws?id=415819 Remittances to a non-resident parent for professional support services, client-related expenses and computer maintenance charges were held not subject to withholding tax under section 195. The professional support services were found not to be technical services and did not satisfy the India-USA treaty's make available requirement for fees for included services. The computer maintenance charges were treated as access to a common global portal, involving no transfer of technology or royalty. The record also did not support taxing the full client-related expense claim, and liability could not be based on a later retrospective enlargement of the charging provision. The withholding addition was deleted. en-us Wed, 10 Nov 2021 00:00:00 +0530 Wed, 15 Dec 2021 09:27:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=415819 Remittances to a non-resident parent for professional support services, client-related expenses and computer maintenance charges were held not subject to withholding tax under section 195. The professional support services were found not to be technical services and did not satisfy the India-USA treaty's make available requirement for fees for included services. The computer maintenance charges were treated as access to a common global portal, involving no transfer of technology or royalty. The record also did not support taxing the full client-related expense claim, and liability could not be based on a later retrospective enlargement of the charging provision. The withholding addition was deleted. Case-Laws Income Tax Wed, 10 Nov 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=415819