https://www.taxtmi.com/caselaws?id=796694 A Finance Act, 2010 amendment to section 9 that removes the requirement for technical services to be rendered in India enlarges the tax charge and cannot retrospectively disturb completed offshore service transactions or vested taxpayer benefits. The notes state that a later legislative amendment, even if expressed retrospectively, does not justify modification of concluded relief, and that withdrawal of beneficial Board circulars operates prospectively. Where more beneficial, Article 12(4) of the India-USA DTAA applies through section 90(2). The amendment is therefore described as prospective, preserving the pre-amendment position and treaty protection for offshore technical-service payments. en-us Thu, 06 Aug 2026 00:00:00 +0530 Sat, 08 Aug 2026 08:32:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796694 A Finance Act, 2010 amendment to section 9 that removes the requirement for technical services to be rendered in India enlarges the tax charge and cannot retrospectively disturb completed offshore service transactions or vested taxpayer benefits. The notes state that a later legislative amendment, even if expressed retrospectively, does not justify modification of concluded relief, and that withdrawal of beneficial Board circulars operates prospectively. Where more beneficial, Article 12(4) of the India-USA DTAA applies through section 90(2). The amendment is therefore described as prospective, preserving the pre-amendment position and treaty protection for offshore technical-service payments. Case-Laws Income Tax Thu, 06 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796694