https://www.taxtmi.com/caselaws?id=309194 Receipts from Indian customers for telecom connectivity services were held not taxable in India as royalty or fees for technical services under section 9 and Article 13 of the India-UK DTAA. The Tribunal treated the connectivity arrangement as a standard service facility, not the use of any copyright, patent, process, equipment, or other proprietary right. Although the services involved technical inputs and sophisticated infrastructure, the technology was not made available to the customers, so the treaty definition of fees for technical services was not met. The assessee therefore succeeded on the substantive taxability issue. en-us Wed, 09 Nov 2016 00:00:00 +0530 Thu, 17 Aug 2023 07:45:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=309194 Receipts from Indian customers for telecom connectivity services were held not taxable in India as royalty or fees for technical services under section 9 and Article 13 of the India-UK DTAA. The Tribunal treated the connectivity arrangement as a standard service facility, not the use of any copyright, patent, process, equipment, or other proprietary right. Although the services involved technical inputs and sophisticated infrastructure, the technology was not made available to the customers, so the treaty definition of fees for technical services was not met. The assessee therefore succeeded on the substantive taxability issue. Case-Laws Income Tax Wed, 09 Nov 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=309194