https://www.taxtmi.com/caselaws?id=59729 The Tribunal held that payments made by Indian Oil Corporation Ltd. (IOC) to a licensor for technical know-how and basic engineering documentation were not royalty but technical fees or business profits. As the services were not provided in India and the licensor did not have a Permanent Establishment in India, the payments were not taxable in India. IOC was not required to deduct tax at source, and the appeals by IOC were allowed. The judgment underscores the significance of distinguishing between royalty payments and technical fees in determining tax liability under international treaties. en-us Wed, 29 Jul 2009 00:00:00 +0530 Sat, 28 Jul 2012 11:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59729 The Tribunal held that payments made by Indian Oil Corporation Ltd. (IOC) to a licensor for technical know-how and basic engineering documentation were not royalty but technical fees or business profits. As the services were not provided in India and the licensor did not have a Permanent Establishment in India, the payments were not taxable in India. IOC was not required to deduct tax at source, and the appeals by IOC were allowed. The judgment underscores the significance of distinguishing between royalty payments and technical fees in determining tax liability under international treaties. Case-Laws Income Tax Wed, 29 Jul 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59729