https://www.taxtmi.com/caselaws?id=59733 Technical or consultancy services rendered outside India are taxable as fees for included services under the Indo-US DTAA only if they make available technical knowledge, experience, skill, know-how or processes to the recipient; mere provision of sophisticated services abroad is insufficient. The receipts were also not taxable as business profits because only profits attributable to the permanent establishment in India can be taxed, and no attribution to that permanent establishment was shown. Where tax was deductible at source under section 195, interest under section 234B was not leviable on the non-resident for failure to pay advance tax. en-us Fri, 03 Jul 2009 00:00:00 +0530 Fri, 29 Sep 2023 22:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59733 Technical or consultancy services rendered outside India are taxable as fees for included services under the Indo-US DTAA only if they make available technical knowledge, experience, skill, know-how or processes to the recipient; mere provision of sophisticated services abroad is insufficient. The receipts were also not taxable as business profits because only profits attributable to the permanent establishment in India can be taxed, and no attribution to that permanent establishment was shown. Where tax was deductible at source under section 195, interest under section 234B was not leviable on the non-resident for failure to pay advance tax. Case-Laws Income Tax Fri, 03 Jul 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59733