https://www.taxtmi.com/caselaws?id=64087 Expatriate technicians' remuneration was not exempt under Article XIV(2) of the India-France tax treaty where it was attributable to an Indian permanent establishment and absorbed in profits computed presumptively under section 44BB. The statutory fiction under section 44BB applies fully, notwithstanding that salary was not separately recorded in Indian books, requiring tax deduction at source and supporting default treatment under section 201(1). Employer-provided boarding and lodging constituted taxable employment perquisites, while off-period salary remained taxable in line with prior treatment. The employer consequently remained liable to deduct tax on expatriate remuneration and related benefits. en-us Thu, 14 Jul 2005 00:00:00 +0530 Fri, 22 Jun 2012 16:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=64087 Expatriate technicians' remuneration was not exempt under Article XIV(2) of the India-France tax treaty where it was attributable to an Indian permanent establishment and absorbed in profits computed presumptively under section 44BB. The statutory fiction under section 44BB applies fully, notwithstanding that salary was not separately recorded in Indian books, requiring tax deduction at source and supporting default treatment under section 201(1). Employer-provided boarding and lodging constituted taxable employment perquisites, while off-period salary remained taxable in line with prior treatment. The employer consequently remained liable to deduct tax on expatriate remuneration and related benefits. Case-Laws Income Tax Thu, 14 Jul 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=64087