https://www.taxtmi.com/caselaws?id=422742 Membership and subscription fees paid to an overseas umbrella association were held not to be royalty or fees for technical services under the India-UK DTAA, because the association did not render services, had no Indian presence, and the payment was a mutual contribution toward shared expenses rather than consideration for intellectual property or technical know-how. A separate payment to a non-resident group entity for work performed outside India was also found not chargeable to tax in India, as the services were rendered outside India, no permanent establishment or fixed base existed in India, and no technical knowledge was made available. Accordingly, no withholding under section 195 was required and the disallowance under section 40(a)(i) was deleted. en-us Fri, 29 Apr 2022 00:00:00 +0530 Fri, 20 May 2022 10:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=422742 Membership and subscription fees paid to an overseas umbrella association were held not to be royalty or fees for technical services under the India-UK DTAA, because the association did not render services, had no Indian presence, and the payment was a mutual contribution toward shared expenses rather than consideration for intellectual property or technical know-how. A separate payment to a non-resident group entity for work performed outside India was also found not chargeable to tax in India, as the services were rendered outside India, no permanent establishment or fixed base existed in India, and no technical knowledge was made available. Accordingly, no withholding under section 195 was required and the disallowance under section 40(a)(i) was deleted. Case-Laws Income Tax Fri, 29 Apr 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=422742