https://www.taxtmi.com/caselaws?id=30867 Fees for bioequivalence and bioanalytical studies were not taxable in India as fees for technical services, fees for included services, or royalty because the service provider only used its own expertise to generate final reports and did not transfer or make available technical knowledge, skill, know-how, or a technical plan to the Indian clients. The receipt of samples and any resulting intellectual property did not alter that position. The income was characterised as business profits, taxable in India only if the non-resident had a permanent establishment in India; none was established on the record, so the income was not chargeable to tax in India. en-us Thu, 11 Sep 2008 00:00:00 +0530 Fri, 24 Oct 2008 18:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=30867 Fees for bioequivalence and bioanalytical studies were not taxable in India as fees for technical services, fees for included services, or royalty because the service provider only used its own expertise to generate final reports and did not transfer or make available technical knowledge, skill, know-how, or a technical plan to the Indian clients. The receipt of samples and any resulting intellectual property did not alter that position. The income was characterised as business profits, taxable in India only if the non-resident had a permanent establishment in India; none was established on the record, so the income was not chargeable to tax in India. Case-Laws Income Tax Thu, 11 Sep 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=30867