https://www.taxtmi.com/highlights?id=96721 Question whether fees for technical services paid to a foreign resident are taxable in India turns on the source of income (where the contract was negotiated and executed), not merely receipt in India; factual dispute exists whether an Indian purchase order reflects an Indian source or whether the contract and performance were effected by an overseas branch, and the assessee failed to place conclusive evidence. The assessee bears the primary onus to prove entitlement to exemption and must produce cogent evidence. Matter remanded to the assessing officer for de novo reassessment and re examination of evidence. en-us Mon, 09 Feb 2026 10:00:04 +0530 Mon, 09 Feb 2026 10:00:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=96721 Question whether fees for technical services paid to a foreign resident are taxable in India turns on the source of income (where the contract was negotiated and executed), not merely receipt in India; factual dispute exists whether an Indian purchase order reflects an Indian source or whether the contract and performance were effected by an overseas branch, and the assessee failed to place conclusive evidence. The assessee bears the primary onus to prove entitlement to exemption and must produce cogent evidence. Matter remanded to the assessing officer for de novo reassessment and re examination of evidence. Highlights Income Tax Mon, 09 Feb 2026 10:00:04 +0530 https://www.taxtmi.com/highlights?id=96721