https://www.taxtmi.com/caselaws?id=786224 Dispute turns on whether fees for technical services are taxable in India by reference to source of income rather than mere receipt; if the contract was sourced and executed by the UAE branch of the payer, the income may fall within the exception to India taxation, but the assessee failed to produce cogent evidence to establish that factual position, so onus remains on the assessee to prove exemption. The matter is remitted to the assessing officer for de novo reassessment with directions for the assessee to submit necessary evidence; a Supreme Court precedent is noted as relevant. en-us Fri, 06 Feb 2026 00:00:00 +0530 Mon, 09 Feb 2026 09:19:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786224 Dispute turns on whether fees for technical services are taxable in India by reference to source of income rather than mere receipt; if the contract was sourced and executed by the UAE branch of the payer, the income may fall within the exception to India taxation, but the assessee failed to produce cogent evidence to establish that factual position, so onus remains on the assessee to prove exemption. The matter is remitted to the assessing officer for de novo reassessment with directions for the assessee to submit necessary evidence; a Supreme Court precedent is noted as relevant. Case-Laws Income Tax Fri, 06 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786224