https://www.taxtmi.com/caselaws?id=63488 Under Article X(k) of the India-Japan treaty, fees for technical services are taxable in the Contracting State where the services are actually rendered. The engineering and management fee was separately identifiable and the record showed that design calculations, planning, testing of materials, and related preparatory work were performed in Japan before the repair work in India. The timing of invoicing or completion statements did not change the place of performance. On that basis, the fee was treated as rendered outside India and not taxable in India under the treaty source rule. en-us Fri, 31 Aug 1990 00:00:00 +0530 Tue, 22 Feb 2011 13:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=63488 Under Article X(k) of the India-Japan treaty, fees for technical services are taxable in the Contracting State where the services are actually rendered. The engineering and management fee was separately identifiable and the record showed that design calculations, planning, testing of materials, and related preparatory work were performed in Japan before the repair work in India. The timing of invoicing or completion statements did not change the place of performance. On that basis, the fee was treated as rendered outside India and not taxable in India under the treaty source rule. Case-Laws Income Tax Fri, 31 Aug 1990 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=63488