https://www.taxtmi.com/caselaws?id=471855 Offshore data-processing receipts generated through an automated standard facility, with no transfer or right to use technology, process, equipment, or intellectual property, do not constitute royalty or fees for technical services under the Income-tax Act. Provider-controlled infrastructure and the absence of constant human intervention or specialised, exclusive technical services support that treatment. Alternative examination as business income falls within the original assessment's scope. Because no DTAA with Hong Kong applied for the relevant year, domestic-law taxability depends on adequately established business connection, source, and Indian nexus; deficient findings on those matters require fresh determination. en-us Mon, 13 Mar 2023 00:00:00 +0530 Mon, 21 Sep 2026 18:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471855 Offshore data-processing receipts generated through an automated standard facility, with no transfer or right to use technology, process, equipment, or intellectual property, do not constitute royalty or fees for technical services under the Income-tax Act. Provider-controlled infrastructure and the absence of constant human intervention or specialised, exclusive technical services support that treatment. Alternative examination as business income falls within the original assessment's scope. Because no DTAA with Hong Kong applied for the relevant year, domestic-law taxability depends on adequately established business connection, source, and Indian nexus; deficient findings on those matters require fresh determination. Case-Laws Income Tax Mon, 13 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471855