https://www.taxtmi.com/caselaws?id=440776 Taxability of foreign receipts for provision of a virtual voice network turned on whether payments constituted royalty/fees for technical services or ordinary service receipts. The court applied the principle that automated technology operating without continuous human intervention does not qualify as technical services; where a standard facility is offered to the public without exclusive bespoke support, it cannot be characterised as making technology available. On those grounds the subscription receipts were treated as payment for services, not fees for technical services or royalty under the DTAA, and no substantial question of law arose. en-us Wed, 19 Jul 2023 00:00:00 +0530 Wed, 11 Feb 2026 12:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=440776 Taxability of foreign receipts for provision of a virtual voice network turned on whether payments constituted royalty/fees for technical services or ordinary service receipts. The court applied the principle that automated technology operating without continuous human intervention does not qualify as technical services; where a standard facility is offered to the public without exclusive bespoke support, it cannot be characterised as making technology available. On those grounds the subscription receipts were treated as payment for services, not fees for technical services or royalty under the DTAA, and no substantial question of law arose. Case-Laws Income Tax Wed, 19 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=440776