https://www.taxtmi.com/caselaws?id=416627 Manpower support linked to engineering and design services was held not taxable as fees for technical or included services because the personnel performed supervisory and coordination functions without making available technical knowledge, skill, know-how or processes to the recipient; in the absence of a permanent establishment in India, the receipt was also not taxable as business profits. Sale of software licences obtained from third parties for redistribution was held not to constitute royalty, as no copyright rights were transferred and the treaty royalty provision requires use of, or right to use, copyright. The additions on both counts were deleted. en-us Tue, 21 Dec 2021 00:00:00 +0530 Mon, 03 Jan 2022 08:27:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=416627 Manpower support linked to engineering and design services was held not taxable as fees for technical or included services because the personnel performed supervisory and coordination functions without making available technical knowledge, skill, know-how or processes to the recipient; in the absence of a permanent establishment in India, the receipt was also not taxable as business profits. Sale of software licences obtained from third parties for redistribution was held not to constitute royalty, as no copyright rights were transferred and the treaty royalty provision requires use of, or right to use, copyright. The additions on both counts were deleted. Case-Laws Income Tax Tue, 21 Dec 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=416627