https://www.taxtmi.com/caselaws?id=64372 The Tribunal dismissed the assessee's appeal, affirming that the non-resident company had a Permanent Establishment (PE) in India under Article 5 of the DTAA, as its activities were conducted on Indian soil and waters. The Tribunal also held that payments received did not constitute fees for technical services, as there was no transfer of technical knowledge. The revenue's appeal was allowed, ruling that mobilization/demobilization charges must be included in the gross revenue for computing presumptive income under section 44BB, following the jurisdictional HC's decisions. en-us Fri, 29 Aug 2008 00:00:00 +0530 Fri, 24 Nov 2023 16:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=64372 The Tribunal dismissed the assessee's appeal, affirming that the non-resident company had a Permanent Establishment (PE) in India under Article 5 of the DTAA, as its activities were conducted on Indian soil and waters. The Tribunal also held that payments received did not constitute fees for technical services, as there was no transfer of technical knowledge. The revenue's appeal was allowed, ruling that mobilization/demobilization charges must be included in the gross revenue for computing presumptive income under section 44BB, following the jurisdictional HC's decisions. Case-Laws Income Tax Fri, 29 Aug 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=64372