https://www.taxtmi.com/caselaws?id=440181 Receipts from offshore sale of equipment, consumables and spare parts were held not to be fees for technical services under section 9(1)(vii) and Article 12 of the India-Ireland DTAA because the invoices and purchase orders reflected sale transactions with quantity, price and buyer details, and did not show consideration for services. The revenue failed to produce clinching material linking the payments to technical assistance, support services or any other service element. On the material available, the receipts were characterised as offshore sale of goods, not service income, and were therefore not taxable as fees for technical services. en-us Mon, 27 Mar 2023 00:00:00 +0530 Wed, 12 Jul 2023 08:03:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=440181 Receipts from offshore sale of equipment, consumables and spare parts were held not to be fees for technical services under section 9(1)(vii) and Article 12 of the India-Ireland DTAA because the invoices and purchase orders reflected sale transactions with quantity, price and buyer details, and did not show consideration for services. The revenue failed to produce clinching material linking the payments to technical assistance, support services or any other service element. On the material available, the receipts were characterised as offshore sale of goods, not service income, and were therefore not taxable as fees for technical services. Case-Laws Income Tax Mon, 27 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=440181