https://www.taxtmi.com/caselaws?id=798221 Payments to non-resident diamond grading and certification entities are not fees for technical services merely because the providers use specialised expertise, equipment or personnel. The relevant inquiry is the nature of the service received: independent reports on diamonds' physical characteristics, without advisory, consultancy, managerial, technical-solution, methodology, know-how or process transfer, do not constitute technical services. Where an applicable treaty requires technical knowledge, experience, skill, know-how or process to be made available, that condition is not met. As the charges are not taxable in India, Section 195 does not require tax deduction at source, and the related demand and interest do not survive. en-us Mon, 31 Aug 2026 00:00:00 +0530 Thu, 03 Sep 2026 08:20:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798221 Payments to non-resident diamond grading and certification entities are not fees for technical services merely because the providers use specialised expertise, equipment or personnel. The relevant inquiry is the nature of the service received: independent reports on diamonds' physical characteristics, without advisory, consultancy, managerial, technical-solution, methodology, know-how or process transfer, do not constitute technical services. Where an applicable treaty requires technical knowledge, experience, skill, know-how or process to be made available, that condition is not met. As the charges are not taxable in India, Section 195 does not require tax deduction at source, and the related demand and interest do not survive. Case-Laws Income Tax Mon, 31 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798221