https://www.taxtmi.com/caselaws?id=780427 Routine repair and replacement work performed by a non-resident vendor for defective ship parts was treated as a works contract and not as technical consultancy or managerial services. Because the foreign personnel stayed in India only briefly, no permanent establishment was found, and no technical knowledge was made available, the receipts were characterised as business profits under Article 7 of the treaty rather than fees for technical services under section 9(1)(vii) or Article 12. On those facts, no withholding obligation arose under section 195, and the conclusion that the assessee was in default under sections 201(1) and 201(1A) was unsustainable. en-us Fri, 17 Oct 2025 00:00:00 +0530 Thu, 30 Oct 2025 08:22:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780427 Routine repair and replacement work performed by a non-resident vendor for defective ship parts was treated as a works contract and not as technical consultancy or managerial services. Because the foreign personnel stayed in India only briefly, no permanent establishment was found, and no technical knowledge was made available, the receipts were characterised as business profits under Article 7 of the treaty rather than fees for technical services under section 9(1)(vii) or Article 12. On those facts, no withholding obligation arose under section 195, and the conclusion that the assessee was in default under sections 201(1) and 201(1A) was unsustainable. Case-Laws Income Tax Fri, 17 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780427