https://www.taxtmi.com/caselaws?id=765497 Advisory and fund-raising fees paid to a Singapore non-resident were treated as service consideration, not royalty or fees for technical services, because the payment did not involve use of intellectual property or other royalty-linked rights and no permanent establishment in India was shown. On that basis, the amount was not chargeable to tax in India as business profits either. As the underlying sum was not taxable, no obligation arose to deduct tax at source under section 195, and the payer could not be treated as an assessee in default or saddled with interest under section 201(1A). en-us Thu, 30 Jan 2025 00:00:00 +0530 Sat, 01 Feb 2025 08:41:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765497 Advisory and fund-raising fees paid to a Singapore non-resident were treated as service consideration, not royalty or fees for technical services, because the payment did not involve use of intellectual property or other royalty-linked rights and no permanent establishment in India was shown. On that basis, the amount was not chargeable to tax in India as business profits either. As the underlying sum was not taxable, no obligation arose to deduct tax at source under section 195, and the payer could not be treated as an assessee in default or saddled with interest under section 201(1A). Case-Laws Income Tax Thu, 30 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765497