https://www.taxtmi.com/caselaws?id=465783 Payments for testing charges, reimbursements, commission, and sales and marketing services were held not to be chargeable to tax in India where the recipient did not make available technical knowledge, skill, or consultancy to the assessee and the treaty conditions for fees for technical or included services were not met. The recipient was also treated as having no permanent establishment in India, reinforcing the non-taxability position. As no tax deduction at source was required on these remittances, disallowance under section 40(a)(ia) was not sustainable. en-us Fri, 24 Jan 2025 00:00:00 +0530 Thu, 08 Jan 2026 21:13:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465783 Payments for testing charges, reimbursements, commission, and sales and marketing services were held not to be chargeable to tax in India where the recipient did not make available technical knowledge, skill, or consultancy to the assessee and the treaty conditions for fees for technical or included services were not met. The recipient was also treated as having no permanent establishment in India, reinforcing the non-taxability position. As no tax deduction at source was required on these remittances, disallowance under section 40(a)(ia) was not sustainable. Case-Laws Income Tax Fri, 24 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465783