https://www.taxtmi.com/caselaws?id=794237 Treaty taxation of software-related payments depended on the make available test: services routed through a US branch were not taxable in India as fees for technical services because no technical knowledge, skill or know-how was shown to have been transferred for independent future use, so no section 195 withholding and no section 40(a)(i) disallowance arose. A licence payment to Forrester Research Ltd. was treated as royalty and the corresponding section 40(a)(i) disallowance was sustained. The section 14A read with Rule 8D disallowance was deleted because the assessment order did not record proper dissatisfaction. CSR donations were eligible for section 80G subject to verification. The Tangent International issue was restored for fresh factual examination. en-us Mon, 29 Jun 2026 00:00:00 +0530 Thu, 02 Jul 2026 08:07:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794237 Treaty taxation of software-related payments depended on the make available test: services routed through a US branch were not taxable in India as fees for technical services because no technical knowledge, skill or know-how was shown to have been transferred for independent future use, so no section 195 withholding and no section 40(a)(i) disallowance arose. A licence payment to Forrester Research Ltd. was treated as royalty and the corresponding section 40(a)(i) disallowance was sustained. The section 14A read with Rule 8D disallowance was deleted because the assessment order did not record proper dissatisfaction. CSR donations were eligible for section 80G subject to verification. The Tangent International issue was restored for fresh factual examination. Case-Laws Income Tax Mon, 29 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794237