https://www.taxtmi.com/caselaws?id=34007 Telecom connectivity payments for carriage of signals were held not to be fees for technical services because no managerial, technical or consultancy service was rendered and no technology, skill or know-how was made available. They were also not royalty, as the payer acquired no right to use intellectual property, equipment or a secret process. The foreign telecom provider was found to have no permanent establishment in India, because there was no fixed place, branch, office, dependent agent or deputed personnel. As the receipts were business profits and no PE existed, the income was not taxable in India and no withholding under section 195 arose. en-us Tue, 30 Jun 2009 00:00:00 +0530 Tue, 18 Nov 2025 17:41:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=34007 Telecom connectivity payments for carriage of signals were held not to be fees for technical services because no managerial, technical or consultancy service was rendered and no technology, skill or know-how was made available. They were also not royalty, as the payer acquired no right to use intellectual property, equipment or a secret process. The foreign telecom provider was found to have no permanent establishment in India, because there was no fixed place, branch, office, dependent agent or deputed personnel. As the receipts were business profits and no PE existed, the income was not taxable in India and no withholding under section 195 arose. Case-Laws Income Tax Tue, 30 Jun 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=34007