https://www.taxtmi.com/caselaws?id=429546 Commission under a non-exclusive commissionaire arrangement for sales support, customer liaison and product promotion was not treated as fees for technical services under the India-Germany DTAA or the Income-tax Act because such ordinary procurement and support functions do not constitute managerial, technical or consultancy services; the related addition was deleted. Subscription receipts for access to online books and journals were also not treated as royalty because the payments covered access to copyrighted content, not transfer or use of copyright or other protected rights; the related addition was deleted. The interest and penalty grounds consequently did not survive. en-us Fri, 14 Oct 2022 00:00:00 +0530 Sat, 25 Nov 2023 12:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=429546 Commission under a non-exclusive commissionaire arrangement for sales support, customer liaison and product promotion was not treated as fees for technical services under the India-Germany DTAA or the Income-tax Act because such ordinary procurement and support functions do not constitute managerial, technical or consultancy services; the related addition was deleted. Subscription receipts for access to online books and journals were also not treated as royalty because the payments covered access to copyrighted content, not transfer or use of copyright or other protected rights; the related addition was deleted. The interest and penalty grounds consequently did not survive. Case-Laws Income Tax Fri, 14 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=429546