https://www.taxtmi.com/caselaws?id=447910 Payments by an Indian resident to a foreign software services provider were held not taxable as fee for technical services because services were rendered and utilized outside India and the source of income was outside India, satisfying exceptions to the source rule; consequence: no tax as FTS. The payments did not constitute infrastructure services or transfer of technical know-how, and absent any permanent establishment in India, amounts qualify as business profits not taxable in India. As a result DTAA and MFN issues were left undecided. Interest under advance tax provisions was not chargeable and interest computation for delay requires recomputation. en-us Wed, 20 Dec 2023 00:00:00 +0530 Tue, 20 Jan 2026 17:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447910 Payments by an Indian resident to a foreign software services provider were held not taxable as fee for technical services because services were rendered and utilized outside India and the source of income was outside India, satisfying exceptions to the source rule; consequence: no tax as FTS. The payments did not constitute infrastructure services or transfer of technical know-how, and absent any permanent establishment in India, amounts qualify as business profits not taxable in India. As a result DTAA and MFN issues were left undecided. Interest under advance tax provisions was not chargeable and interest computation for delay requires recomputation. Case-Laws Income Tax Wed, 20 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447910