Royalties/Fee for technical services – Make available : Where assessee, a global pharmaceutical company, made foreign remittances to various parties against clinical trial services, since services provided by non-residents did not involve any transfer of technology and it was not even case of Assessing Officer that assessee was enabled to perform these services on its own without any future recourse to service provider, said payment was not for technical services and, hence, not liable for TDS – Deputy Commissioner of Income-tax (International Taxation) v. Zydus Lifescience Ltd. – [2024] 163 taxmann.com 48 (Ahmedabad – Trib.)
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