https://www.taxtmi.com/caselaws?id=307020 A tribunal precedent applied a six-year limitation period for initiation of proceedings under section 201 against resident and non-resident payers, and the order for FY 2010-11 was found time barred on that basis. On the merits, marketing and facilitation services involving lead generation, market research, negotiation support, contract facilitation and collection support were held not to make available technical knowledge, skill, know-how or process. The receipts were therefore treated as neither royalty under section 9(1)(vi) nor fees for technical or included services under section 9(1)(vii) read with Article 12 of the India-USA DTAA, so no TDS obligation survived. en-us Fri, 20 Mar 2020 00:00:00 +0530 Mon, 13 Mar 2023 21:54:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307020 A tribunal precedent applied a six-year limitation period for initiation of proceedings under section 201 against resident and non-resident payers, and the order for FY 2010-11 was found time barred on that basis. On the merits, marketing and facilitation services involving lead generation, market research, negotiation support, contract facilitation and collection support were held not to make available technical knowledge, skill, know-how or process. The receipts were therefore treated as neither royalty under section 9(1)(vi) nor fees for technical or included services under section 9(1)(vii) read with Article 12 of the India-USA DTAA, so no TDS obligation survived. Case-Laws Income Tax Fri, 20 Mar 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307020