https://www.taxtmi.com/caselaws?id=786224 Taxability of fees for technical services paid to a UAE resident turned on whether the services were sourced and consumed outside India, because the assessee invoked the exception to the deeming rule for income accruing in India. The record was not conclusive on who contracted for and utilised the services, so the factual foundation for the exemption claim was found to need fresh examination. The matter was remanded for de novo reassessment after verification of the relevant evidence, and the alternative treaty contention was left open as academic at that stage. 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 Taxability of fees for technical services paid to a UAE resident turned on whether the services were sourced and consumed outside India, because the assessee invoked the exception to the deeming rule for income accruing in India. The record was not conclusive on who contracted for and utilised the services, so the factual foundation for the exemption claim was found to need fresh examination. The matter was remanded for de novo reassessment after verification of the relevant evidence, and the alternative treaty contention was left open as academic at that stage. Case-Laws Income Tax Fri, 06 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786224