In a recent ruling, the Indian Supreme Court found that the past interpretation of technical services is no longer adequate because of the effects of modern technology and automation, and that a new interpretation must be adopted. The case involved Kotak Securities Ltd. (Kotak) and its payments of transactions fees to the Bombay Stock Exchange, which the assessing officer determined were fees for technical services (FTS) and subject to tax withholding at source. Because Kotak did not withhold…