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Royalties/fees for technical services – Marketing services 

SLP dismissed against impugned order of High Court that where assessee-company made payments to US Company for marketing services and scope of work was to generate customer leads using/subscribing customer data base, market research, analysis, and online research data and that service provider had not made available any technical knowledge, experience, knowhow, process to develop and transfer technical plan or technical design, in view of admitted fact that services were utilized in USA, payments so made could not be considered as royalty or FTS and hence, no TDS was required to be deducted – Commissioner of Income tax, IT v. Ad2pro Media Solutions (P.) Ltd. – [2024] 158 taxmann.com 408 (SC)

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