https://www.taxtmi.com/caselaws?id=470029 Buying agency services involving vendor identification, order placement, negotiation, quality checks, logistics and compliance support are described as procurement and commercial agency activities rather than managerial, technical or consultancy services under Article 12(4) of the India-Switzerland DTAA, where no technical knowledge, know-how or process is transferred. The notes state that such receipts retain the character of business income under Article 7 and are not taxable in India without a permanent establishment. They also explain that Section 144C permits the Dispute Resolution Panel to examine matters arising from assessment proceedings and recharacterise income, provided the taxpayer receives an effective opportunity to respond. The described analysis therefore separates substantive treaty classification from procedural jurisdiction and natural justice. en-us Mon, 03 Nov 2025 00:00:00 +0530 Mon, 13 Jul 2026 18:58:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470029 Buying agency services involving vendor identification, order placement, negotiation, quality checks, logistics and compliance support are described as procurement and commercial agency activities rather than managerial, technical or consultancy services under Article 12(4) of the India-Switzerland DTAA, where no technical knowledge, know-how or process is transferred. The notes state that such receipts retain the character of business income under Article 7 and are not taxable in India without a permanent establishment. They also explain that Section 144C permits the Dispute Resolution Panel to examine matters arising from assessment proceedings and recharacterise income, provided the taxpayer receives an effective opportunity to respond. The described analysis therefore separates substantive treaty classification from procedural jurisdiction and natural justice. Case-Laws Income Tax Mon, 03 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470029