https://www.taxtmi.com/caselaws?id=466570 Whether payments for purchase of VoIP minutes constituted fees for technical services and attracted tax withholding and disallowance was decided by applying the legal test that fully automated services without human intervention do not amount to technical services. The Tribunal found the supplier to be an intermediary procuring and reselling network capacity, with services delivered by automated processes and no technical personnel made available in India; it therefore held there was no fee for technical services, no permanent establishment, no obligation to deduct tax at source, and deleted the disallowance under the taxpayer provisions. en-us Thu, 27 Feb 2025 00:00:00 +0530 Wed, 11 Feb 2026 11:51:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466570 Whether payments for purchase of VoIP minutes constituted fees for technical services and attracted tax withholding and disallowance was decided by applying the legal test that fully automated services without human intervention do not amount to technical services. The Tribunal found the supplier to be an intermediary procuring and reselling network capacity, with services delivered by automated processes and no technical personnel made available in India; it therefore held there was no fee for technical services, no permanent establishment, no obligation to deduct tax at source, and deleted the disallowance under the taxpayer provisions. Case-Laws Income Tax Thu, 27 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466570