https://www.taxtmi.com/caselaws?id=63315 A non-resident contractor's project profits from an Indian permanent establishment were treated as taxable in India on a broader attribution basis under section 5(2), section 9(1)(i) and Article 7 of the India-Canada treaty, which follows the UN Model and extends taxing rights to profits from similar activities carried on through the establishment. The document also notes that the receipts were alternatively characterised as fees for technical services, allowing computation under section 44D read with section 115A. An addition for alleged suppressed contractual receipts was deleted because the taxpayer followed the percentage completion method and the relevant revenue was recognised in the subsequent year. Connected expense disallowances and interest under sections 234B and 234C did not survive. en-us Fri, 30 Mar 2007 00:00:00 +0530 Sat, 17 Feb 2024 10:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=63315 A non-resident contractor's project profits from an Indian permanent establishment were treated as taxable in India on a broader attribution basis under section 5(2), section 9(1)(i) and Article 7 of the India-Canada treaty, which follows the UN Model and extends taxing rights to profits from similar activities carried on through the establishment. The document also notes that the receipts were alternatively characterised as fees for technical services, allowing computation under section 44D read with section 115A. An addition for alleged suppressed contractual receipts was deleted because the taxpayer followed the percentage completion method and the relevant revenue was recognised in the subsequent year. Connected expense disallowances and interest under sections 234B and 234C did not survive. Case-Laws Income Tax Fri, 30 Mar 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=63315