Dismissing the appeal the Court held thatPayment for installation of wind turbine, repairs to wind Turbine and for market study. Services rendered technical in nature and payments were fees for technical services is liable to deduction of tax at source. No substantial question of law . ( AY . 2014 -15)
Regen Powertech P. Ltd. v. DCIT ( 2019) 416 ITR 95 (Mad) (HC)
S. 9(1)(vii):Income deemed to accrue or arise in India – Fees for technical services – Payment for installation of wind turbine, repairs to wind Turbine and for market study — Services rendered technical in nature -Liable to deduction of tax at source- DTAA -India – Sri Lanka . [ S.195 , 260A, Art, (12)(2) . ]