https://www.taxtmi.com/caselaws?id=792766 Receipts characterised as fee for technical services from Indian group companies were held not taxable in India under the residuary article of the India-Thailand treaty or section 9(1)(vii) where the treaty had no specific fee-for-technical-services article and the income was capable of examination under the business profits article; in the absence of a permanent establishment in India, the residuary article could not be used to tax such income. Interest under sections 234A and 234B was left for limited verification on the return filing date and consequential tax position, while the challenge to initiation of penalty proceedings under section 270A was treated as premature. en-us Fri, 29 May 2026 00:00:00 +0530 Wed, 03 Jun 2026 08:50:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792766 Receipts characterised as fee for technical services from Indian group companies were held not taxable in India under the residuary article of the India-Thailand treaty or section 9(1)(vii) where the treaty had no specific fee-for-technical-services article and the income was capable of examination under the business profits article; in the absence of a permanent establishment in India, the residuary article could not be used to tax such income. Interest under sections 234A and 234B was left for limited verification on the return filing date and consequential tax position, while the challenge to initiation of penalty proceedings under section 270A was treated as premature. Case-Laws Income Tax Fri, 29 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792766