https://www.taxtmi.com/caselaws?id=792069 Advisory and consultative services rendered by a UAE-based consultant were not taxable as fees for technical services because the work was limited to review, comments, suggestions, and supervisory inputs, with no making available of technical knowledge, skill, or know-how for independent future use. In the absence of a treaty article taxing such income and with no permanent establishment in India, domestic law could not be used to enlarge treaty chargeability. The remittance was therefore outside the taxable category, the payer had no obligation to deduct tax at source, and the demand under sections 201(1) and 201(1A) failed. en-us Wed, 20 May 2026 00:00:00 +0530 Fri, 22 May 2026 07:06:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792069 Advisory and consultative services rendered by a UAE-based consultant were not taxable as fees for technical services because the work was limited to review, comments, suggestions, and supervisory inputs, with no making available of technical knowledge, skill, or know-how for independent future use. In the absence of a treaty article taxing such income and with no permanent establishment in India, domestic law could not be used to enlarge treaty chargeability. The remittance was therefore outside the taxable category, the payer had no obligation to deduct tax at source, and the demand under sections 201(1) and 201(1A) failed. Case-Laws Income Tax Wed, 20 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792069