https://www.taxtmi.com/caselaws?id=794064 Receipts from routine back-office support services to Indian affiliates were held not to be royalty, because the services did not involve transfer or use of copyright, designs, plans, secret formulae, processes or similar intellectual or technical rights; with no fees-for-technical-services article in the DTAA, the receipts were examined as business profits and, absent a permanent establishment in India, were not taxable. The levy of fee under section 234F and interest under section 234A were restored for verification of the return-filing date and the statutory due date. The challenge to initiation of penalty under section 270A was rejected as premature. en-us Wed, 24 Jun 2026 00:00:00 +0530 Mon, 29 Jun 2026 09:28:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794064 Receipts from routine back-office support services to Indian affiliates were held not to be royalty, because the services did not involve transfer or use of copyright, designs, plans, secret formulae, processes or similar intellectual or technical rights; with no fees-for-technical-services article in the DTAA, the receipts were examined as business profits and, absent a permanent establishment in India, were not taxable. The levy of fee under section 234F and interest under section 234A were restored for verification of the return-filing date and the statutory due date. The challenge to initiation of penalty under section 270A was rejected as premature. Case-Laws Income Tax Wed, 24 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794064