https://www.taxtmi.com/caselaws?id=462143 TDS under section 195, deeming an assessee in default under section 201, and the characterisation of payroll services rendered by IBM Philippines as fees for technical services are the central issues, along with whether a permanent establishment existed and how the DTAA operates vis-a -vis domestic law under section 90. The record also notes that applications for condonation of delay in filing the Special Leave Petitions, exemption from filing certified copies, and interim relief were listed, notice was issued, service was completed, and the matters were disposed of together on motion hearing. en-us Tue, 24 Sep 2024 00:00:00 +0530 Tue, 27 May 2025 12:44:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462143 TDS under section 195, deeming an assessee in default under section 201, and the characterisation of payroll services rendered by IBM Philippines as fees for technical services are the central issues, along with whether a permanent establishment existed and how the DTAA operates vis-a -vis domestic law under section 90. The record also notes that applications for condonation of delay in filing the Special Leave Petitions, exemption from filing certified copies, and interim relief were listed, notice was issued, service was completed, and the matters were disposed of together on motion hearing. Case-Laws Income Tax Tue, 24 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462143