https://www.taxtmi.com/article/detailed?id=11232 Payments to a foreign affiliate for outsourced payroll and related human-resources services qualified as business income of the foreign affiliate, not as technical services; absent a permanent establishment in India and in view of the treaty allocation of taxing rights, such payments were not subject to domestic withholding tax and the payer could not be treated as an assessee in default for failing to deduct tax. en-us Thu, 23 Mar 2023 12:44:50 +0530 Thu, 23 Mar 2023 12:44:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=11232 Payments to a foreign affiliate for outsourced payroll and related human-resources services qualified as business income of the foreign affiliate, not as technical services; absent a permanent establishment in India and in view of the treaty allocation of taxing rights, such payments were not subject to domestic withholding tax and the payer could not be treated as an assessee in default for failing to deduct tax. Articles Income Tax Thu, 23 Mar 2023 12:44:50 +0530 https://www.taxtmi.com/article/detailed?id=11232