https://www.taxtmi.com/caselaws?id=435720 Payments for freshly created tower design services were treated as fees for technical services, not royalty, because the arrangement involved project study, drawings and test data created for the payer's specifications rather than use of pre-existing copyrighted design rights. The commentary also states that, where the India-UAE treaty contains no fees for technical services article and the UAE recipient has no permanent establishment in India, such payments are not taxable in India under treaty principles. On that basis, no withholding tax obligation arises on the remittance. en-us Tue, 21 Mar 2023 00:00:00 +0530 Thu, 21 May 2026 17:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=435720 Payments for freshly created tower design services were treated as fees for technical services, not royalty, because the arrangement involved project study, drawings and test data created for the payer's specifications rather than use of pre-existing copyrighted design rights. The commentary also states that, where the India-UAE treaty contains no fees for technical services article and the UAE recipient has no permanent establishment in India, such payments are not taxable in India under treaty principles. On that basis, no withholding tax obligation arises on the remittance. Case-Laws Income Tax Tue, 21 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=435720