https://www.taxtmi.com/caselaws?id=440345 Business support functions under a commissionaire arrangement, limited to sales promotion, distribution, customer support, order handling, inventory and debtor management, invoicing and delivery, were held not to constitute managerial, technical or consultancy services under the Income-tax Act and the India-Germany DTAA; the commission was therefore not taxable as fees for technical services. Subscription receipts from e-journals were also held not to be fees for technical services because no specialised managerial, technical or consultancy service was shown, and not royalty because subscribers received only access to copyrighted publications without any right in the copyright itself. The additions deleted by the Tribunal were upheld, and the revenue's appeal failed. en-us Wed, 12 Jul 2023 00:00:00 +0530 Mon, 27 Nov 2023 10:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=440345 Business support functions under a commissionaire arrangement, limited to sales promotion, distribution, customer support, order handling, inventory and debtor management, invoicing and delivery, were held not to constitute managerial, technical or consultancy services under the Income-tax Act and the India-Germany DTAA; the commission was therefore not taxable as fees for technical services. Subscription receipts from e-journals were also held not to be fees for technical services because no specialised managerial, technical or consultancy service was shown, and not royalty because subscribers received only access to copyrighted publications without any right in the copyright itself. The additions deleted by the Tribunal were upheld, and the revenue's appeal failed. Case-Laws Income Tax Wed, 12 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=440345