https://www.taxtmi.com/caselaws?id=34007 AAR held that payments by the Indian applicant to the foreign telecom provider for onward carriage of international calls are business profits, not fees for technical services or royalties. The foreign provider did not render technical services, transfer technology, or grant use of any secret process, nor install equipment in India. The applicant acted independently on a principal-to-principal basis and did not create a permanent establishment for the foreign provider in India. Consequently the foreign income is not taxable in India and no deduction at source under section 195 is required; all questions answered in the negative. 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 AAR held that payments by the Indian applicant to the foreign telecom provider for onward carriage of international calls are business profits, not fees for technical services or royalties. The foreign provider did not render technical services, transfer technology, or grant use of any secret process, nor install equipment in India. The applicant acted independently on a principal-to-principal basis and did not create a permanent establishment for the foreign provider in India. Consequently the foreign income is not taxable in India and no deduction at source under section 195 is required; all questions answered in the negative. Case-Laws Income Tax Tue, 30 Jun 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=34007