https://www.taxtmi.com/caselaws?id=755215 Commissionaire services comprising sales promotion, distribution, customer support, order handling, inventory and debtor management, invoicing, delivery and subscription support were held not to constitute fees for technical services under section 9(1)(vii) or Article 12(4), because they did not require specialised technical skill, managerial control or professional advice; the commission income was therefore not taxable as FTS. Subscription collections made on behalf of affiliated publishers were treated as consideration for sale of copyrighted publications, not as technical or consultancy services and not as royalty, because no copyright right was transferred to subscribers; that receipt was therefore not taxable as FTS or royalty and the additions were deleted. en-us Fri, 05 Jul 2024 00:00:00 +0530 Mon, 08 Jul 2024 17:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755215 Commissionaire services comprising sales promotion, distribution, customer support, order handling, inventory and debtor management, invoicing, delivery and subscription support were held not to constitute fees for technical services under section 9(1)(vii) or Article 12(4), because they did not require specialised technical skill, managerial control or professional advice; the commission income was therefore not taxable as FTS. Subscription collections made on behalf of affiliated publishers were treated as consideration for sale of copyrighted publications, not as technical or consultancy services and not as royalty, because no copyright right was transferred to subscribers; that receipt was therefore not taxable as FTS or royalty and the additions were deleted. Case-Laws Income Tax Fri, 05 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755215