https://www.taxtmi.com/caselaws?id=470029 Buying agency commission for vendor identification, order placement, price negotiation, quality checks, logistics coordination and compliance support does not constitute fees for technical services under Article 12(4) of the India-Switzerland DTAA where no managerial, technical or consultancy expertise, know-how or process is transferred to the Indian payer. Such procurement support remains business income and is not taxable in India without a permanent establishment. Section 144C permits the Dispute Resolution Panel to consider and recharacterise matters arising from assessment proceedings, including proposed variations in a draft assessment order. Recharacterisation must nevertheless follow natural justice; an effective opportunity to respond through submissions and a remand process satisfies that requirement. 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 commission for vendor identification, order placement, price negotiation, quality checks, logistics coordination and compliance support does not constitute fees for technical services under Article 12(4) of the India-Switzerland DTAA where no managerial, technical or consultancy expertise, know-how or process is transferred to the Indian payer. Such procurement support remains business income and is not taxable in India without a permanent establishment. Section 144C permits the Dispute Resolution Panel to consider and recharacterise matters arising from assessment proceedings, including proposed variations in a draft assessment order. Recharacterisation must nevertheless follow natural justice; an effective opportunity to respond through submissions and a remand process satisfies that requirement. Case-Laws Income Tax Mon, 03 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470029