https://www.taxtmi.com/caselaws?id=427879 Payments for administration and business support services to an Australian group entity were not fees for technical services under the India-Australia DTAA because the arrangement covered standard group support functions and did not make available technical knowledge, skill, know-how or processes. Nil withholding certificates previously issued under section 195(2) for similar payments on the same contractual arrangement remained unaltered, and no material showed any change in facts. On that basis, no tax was deductible at source under section 195, so disallowance under section 40(a)(i) was not warranted and the addition was deleted. en-us Mon, 12 Sep 2022 00:00:00 +0530 Mon, 19 Sep 2022 09:35:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=427879 Payments for administration and business support services to an Australian group entity were not fees for technical services under the India-Australia DTAA because the arrangement covered standard group support functions and did not make available technical knowledge, skill, know-how or processes. Nil withholding certificates previously issued under section 195(2) for similar payments on the same contractual arrangement remained unaltered, and no material showed any change in facts. On that basis, no tax was deductible at source under section 195, so disallowance under section 40(a)(i) was not warranted and the addition was deleted. Case-Laws Income Tax Mon, 12 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=427879