https://www.taxtmi.com/caselaws?id=437665 Payments to non-resident service providers for overseas ad film production and related logistics were treated as business income, not fees for technical services, because the services were commercial and contract-based rather than managerial, technical or consultancy services. As the non-residents had no permanent establishment in India and the services were rendered and utilised outside India, the receipts were not chargeable to tax in India. No obligation to withhold tax arose, and disallowance under section 40(a)(ia) could not be sustained. en-us Mon, 08 May 2023 00:00:00 +0530 Fri, 12 May 2023 08:27:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=437665 Payments to non-resident service providers for overseas ad film production and related logistics were treated as business income, not fees for technical services, because the services were commercial and contract-based rather than managerial, technical or consultancy services. As the non-residents had no permanent establishment in India and the services were rendered and utilised outside India, the receipts were not chargeable to tax in India. No obligation to withhold tax arose, and disallowance under section 40(a)(ia) could not be sustained. Case-Laws Income Tax Mon, 08 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=437665