https://www.taxtmi.com/caselaws?id=465627 Payments to non-resident group entities for services rendered outside India were treated as not chargeable to tax where the relevant treaties did not permit taxation absent making available technical knowledge, or where the receipts fell within business profits or independent personal services provisions without a permanent establishment or fixed base in India; on that basis, disallowance under section 40(a)(i) was not sustainable. Remittances to KPMG International Co-operative, Switzerland were treated as mutuality-based receipts, not royalty or taxable income, so tax deduction at source was not required and the related disallowance failed. The foreign tax credit claim for taxes paid in Japan was not decided finally and was remitted for verification of payment facts. en-us Tue, 06 Jun 2023 00:00:00 +0530 Sat, 03 Jan 2026 08:03:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465627 Payments to non-resident group entities for services rendered outside India were treated as not chargeable to tax where the relevant treaties did not permit taxation absent making available technical knowledge, or where the receipts fell within business profits or independent personal services provisions without a permanent establishment or fixed base in India; on that basis, disallowance under section 40(a)(i) was not sustainable. Remittances to KPMG International Co-operative, Switzerland were treated as mutuality-based receipts, not royalty or taxable income, so tax deduction at source was not required and the related disallowance failed. The foreign tax credit claim for taxes paid in Japan was not decided finally and was remitted for verification of payment facts. Case-Laws Income Tax Tue, 06 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465627