https://www.taxtmi.com/caselaws?id=63981 FOB equipment sales completed in France, with title and risk passing there and no Indian operations relating to the supplies, did not create taxable business profits in India under section 9(1)(i); installation supervision and a principal-to-principal support arrangement did not establish a permanent establishment. Expenses actually incurred in India for engineers and related technical services were fully deductible against technical service fees under the applicable treaty provision. Section 44D's restriction on deductions in computing royalty or technical-fee income did not displace the separate same-head set-off rule: loss from technical service fees could be adjusted against royalty income. en-us Mon, 20 Sep 1993 00:00:00 +0530 Tue, 22 Feb 2011 13:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=63981 FOB equipment sales completed in France, with title and risk passing there and no Indian operations relating to the supplies, did not create taxable business profits in India under section 9(1)(i); installation supervision and a principal-to-principal support arrangement did not establish a permanent establishment. Expenses actually incurred in India for engineers and related technical services were fully deductible against technical service fees under the applicable treaty provision. Section 44D's restriction on deductions in computing royalty or technical-fee income did not displace the separate same-head set-off rule: loss from technical service fees could be adjusted against royalty income. Case-Laws Income Tax Mon, 20 Sep 1993 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=63981