https://www.taxtmi.com/caselaws?id=468134 Fees received by an overseas investment banker from Indian companies for services performed outside India were not taxable in India as fees for technical services. The services did not fall within income deemed to accrue or arise in India merely because the Indian payer benefited from them. The India-UK DTAA was also examined, and the receipt failed the treaty's make available requirement for technical services. On that basis, the addition was unsustainable and the amount was not taxable in India. en-us Fri, 11 Oct 2019 00:00:00 +0530 Fri, 17 Apr 2026 16:13:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468134 Fees received by an overseas investment banker from Indian companies for services performed outside India were not taxable in India as fees for technical services. The services did not fall within income deemed to accrue or arise in India merely because the Indian payer benefited from them. The India-UK DTAA was also examined, and the receipt failed the treaty's make available requirement for technical services. On that basis, the addition was unsustainable and the amount was not taxable in India. Case-Laws Income Tax Fri, 11 Oct 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468134