https://www.taxtmi.com/caselaws?id=64087 The article examines whether remuneration paid to expatriate technicians was exempt under Article XIV(2) of the France DTAA and how section 44BB affects attribution to an Indian permanent establishment. It explains that the treaty exemption was denied because the remuneration was treated as absorbed in the presumptive computation of PE profits, so tax deduction at source remained applicable and section 201(1) consequences followed. It also notes that the deeming fiction in section 44BB was carried through to expatriate remuneration, while free boarding and lodging were treated as employment perquisites and off-period salary was included for TDS purposes. 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 The article examines whether remuneration paid to expatriate technicians was exempt under Article XIV(2) of the France DTAA and how section 44BB affects attribution to an Indian permanent establishment. It explains that the treaty exemption was denied because the remuneration was treated as absorbed in the presumptive computation of PE profits, so tax deduction at source remained applicable and section 201(1) consequences followed. It also notes that the deeming fiction in section 44BB was carried through to expatriate remuneration, while free boarding and lodging were treated as employment perquisites and off-period salary was included for TDS purposes. Case-Laws Income Tax Thu, 14 Jul 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=64087