https://www.taxtmi.com/caselaws?id=63316 Supervisory receipts were treated as taxable at the treaty rate for fees for technical services because the Revenue did not establish that the contracts were effectively connected with a permanent establishment in India. The Tribunal noted that the liaison office did not constitute a permanent establishment for the supervisory services, the purchase orders and supervision contracts were separate and severable, and the relevant treaty threshold for supervision was not exceeded. A fresh plea that the supervision fee formed part of the equipment supply contract was rejected because it required new factual inquiry not available on record and had not been raised before the lower authorities. Interest under sections 234B and 234C was held not leviable where tax was deductible at source. en-us Thu, 31 May 2007 00:00:00 +0530 Tue, 28 May 2024 10:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=63316 Supervisory receipts were treated as taxable at the treaty rate for fees for technical services because the Revenue did not establish that the contracts were effectively connected with a permanent establishment in India. The Tribunal noted that the liaison office did not constitute a permanent establishment for the supervisory services, the purchase orders and supervision contracts were separate and severable, and the relevant treaty threshold for supervision was not exceeded. A fresh plea that the supervision fee formed part of the equipment supply contract was rejected because it required new factual inquiry not available on record and had not been raised before the lower authorities. Interest under sections 234B and 234C was held not leviable where tax was deductible at source. Case-Laws Income Tax Thu, 31 May 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=63316