https://www.taxtmi.com/caselaws?id=64778 The Tribunal ruled in favor of the non-resident Japanese company, classifying supervision fee as business income rather than a fee for technical services. Income was computed on a completed contract basis, resulting in a modified assessment. Disallowance of expenses was overturned due to available details, adjusting the business income for the relevant assessment years. The attribution of profits from the supply of machinery to the permanent establishment in India was rejected, affirming that profits from the transaction were not assessable in India. The consolidated order partially allowed the assessee's appeal and dismissed the Revenue's appeal, clarifying the tax treatment of income sources. en-us Fri, 17 Jun 1994 00:00:00 +0530 Wed, 09 Feb 2011 17:41:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=64778 The Tribunal ruled in favor of the non-resident Japanese company, classifying supervision fee as business income rather than a fee for technical services. Income was computed on a completed contract basis, resulting in a modified assessment. Disallowance of expenses was overturned due to available details, adjusting the business income for the relevant assessment years. The attribution of profits from the supply of machinery to the permanent establishment in India was rejected, affirming that profits from the transaction were not assessable in India. The consolidated order partially allowed the assessee's appeal and dismissed the Revenue's appeal, clarifying the tax treatment of income sources. Case-Laws Income Tax Fri, 17 Jun 1994 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=64778