https://www.taxtmi.com/caselaws?id=63841 Fees for preparing detailed project reports, technical drawings and engineering designs for highway works were treated as fees for included services under Article 12(4)(b) of the India-Canada DTAA because the payment involved development and transfer of a technical plan or technical design; on that basis, the treaty rate of 15% applied rather than the rate under section 115A. The text also states that interest under section 234B was not leviable where tax was deductible at source and credit for such tax was to be considered in computing advance tax liability, leaving no independent advance-tax default. en-us Fri, 29 Aug 2008 00:00:00 +0530 Fri, 24 Nov 2023 16:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=63841 Fees for preparing detailed project reports, technical drawings and engineering designs for highway works were treated as fees for included services under Article 12(4)(b) of the India-Canada DTAA because the payment involved development and transfer of a technical plan or technical design; on that basis, the treaty rate of 15% applied rather than the rate under section 115A. The text also states that interest under section 234B was not leviable where tax was deductible at source and credit for such tax was to be considered in computing advance tax liability, leaving no independent advance-tax default. Case-Laws Income Tax Fri, 29 Aug 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=63841