https://www.taxtmi.com/caselaws?id=419974 Outsourced automated data-processing services, without transfer of rights in intellectual property, processes or technology, do not constitute royalty. Standard facilities performed by computers without continual human intervention or application of mind do not constitute fees for technical services. Taxing the receipts as business income or on the basis of business connection cannot be introduced where those issues fall outside the scope of remand directions. Tax liability, including the applicable concessional rate, requires recomputation after adequate opportunity to the taxpayer. Undisputed tax deducted at source credit must be granted; issues contingent on the principal taxability findings become infructuous. en-us Tue, 01 Mar 2022 00:00:00 +0530 Wed, 11 Feb 2026 12:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=419974 Outsourced automated data-processing services, without transfer of rights in intellectual property, processes or technology, do not constitute royalty. Standard facilities performed by computers without continual human intervention or application of mind do not constitute fees for technical services. Taxing the receipts as business income or on the basis of business connection cannot be introduced where those issues fall outside the scope of remand directions. Tax liability, including the applicable concessional rate, requires recomputation after adequate opportunity to the taxpayer. Undisputed tax deducted at source credit must be granted; issues contingent on the principal taxability findings become infructuous. Case-Laws Income Tax Tue, 01 Mar 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=419974