https://www.taxtmi.com/caselaws?id=756722 Pure reimbursements paid to foreign entities were treated as non-taxable in India because they contained no income element, so no tax deduction obligation arose under section 195 and disallowance under section 40(a)(i) could not be made. Services used outside India for earning income from foreign sources were held to fall within the statutory exclusion in section 9(1)(vii)(b), again leaving no basis for withholding tax or disallowance. Payments for course material, examination fees and licensed training arrangements were not treated as fees for technical services or royalty where the relevant exclusions and treaty conditions applied, including the requirement that technical knowledge be made available. A consultant payment was also treated as taxable only in the residence country under the treaty, not in India. en-us Mon, 05 Aug 2024 00:00:00 +0530 Mon, 05 Jan 2026 11:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756722 Pure reimbursements paid to foreign entities were treated as non-taxable in India because they contained no income element, so no tax deduction obligation arose under section 195 and disallowance under section 40(a)(i) could not be made. Services used outside India for earning income from foreign sources were held to fall within the statutory exclusion in section 9(1)(vii)(b), again leaving no basis for withholding tax or disallowance. Payments for course material, examination fees and licensed training arrangements were not treated as fees for technical services or royalty where the relevant exclusions and treaty conditions applied, including the requirement that technical knowledge be made available. A consultant payment was also treated as taxable only in the residence country under the treaty, not in India. Case-Laws Income Tax Mon, 05 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756722