https://www.taxtmi.com/caselaws?id=794988 Retrospective amendments to the assessment limitation framework are described as confining the statutory timelines to forwarding the draft assessment order, with DRP proceedings and finalisation thereafter governed independently; the limitation objection to the final order therefore does not survive. Buying agency commission for vendor sourcing, price negotiation, order placement, quality checks, logistics and compliance support is characterised as commercial procurement support rather than managerial, technical or consultancy services under the India-Swiss DTAA. It consequently retains the character of business income and, where the non-resident has no permanent establishment in India, is not chargeable to Indian tax. The related interest issue is consequential. en-us Fri, 12 Jun 2026 00:00:00 +0530 Wed, 15 Jul 2026 08:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794988 Retrospective amendments to the assessment limitation framework are described as confining the statutory timelines to forwarding the draft assessment order, with DRP proceedings and finalisation thereafter governed independently; the limitation objection to the final order therefore does not survive. Buying agency commission for vendor sourcing, price negotiation, order placement, quality checks, logistics and compliance support is characterised as commercial procurement support rather than managerial, technical or consultancy services under the India-Swiss DTAA. It consequently retains the character of business income and, where the non-resident has no permanent establishment in India, is not chargeable to Indian tax. The related interest issue is consequential. Case-Laws Income Tax Fri, 12 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794988