https://www.taxtmi.com/caselaws?id=761375 Automated telecom interconnectivity and roaming receipts were held not to be fee for technical services because the facility operated through a standard automated system without human intervention, and the statutory meaning of technical services requires a human element. The receipts also could not be taxed as other income under the India-Oman DTAA because they were business profits covered by Article 7, and in the absence of a permanent establishment in India they were not taxable in India. The addition was deleted on both substantive taxability grounds. en-us Thu, 24 Oct 2024 00:00:00 +0530 Fri, 08 Nov 2024 12:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761375 Automated telecom interconnectivity and roaming receipts were held not to be fee for technical services because the facility operated through a standard automated system without human intervention, and the statutory meaning of technical services requires a human element. The receipts also could not be taxed as other income under the India-Oman DTAA because they were business profits covered by Article 7, and in the absence of a permanent establishment in India they were not taxable in India. The addition was deleted on both substantive taxability grounds. Case-Laws Income Tax Thu, 24 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761375