https://www.taxtmi.com/caselaws?id=65257 Supervisory activities carried on in connection with an installation or assembly project can create a service permanent establishment under the relevant DTAA clause even when the project does not belong to the non-resident, provided the six-month threshold is met. Control or ownership of the site is not a necessary condition. Once the treaty exemption for fees for technical services does not apply, the income attributable to the permanent establishment is computed under article 7 and the applicable domestic provisions for the relevant period, with no deduction of expenditure under section 44D(b) and tax charged at 30 per cent under section 115A; section 44DA was held inapplicable for that assessment period. en-us Fri, 11 Aug 2006 00:00:00 +0530 Thu, 28 Jun 2012 15:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=65257 Supervisory activities carried on in connection with an installation or assembly project can create a service permanent establishment under the relevant DTAA clause even when the project does not belong to the non-resident, provided the six-month threshold is met. Control or ownership of the site is not a necessary condition. Once the treaty exemption for fees for technical services does not apply, the income attributable to the permanent establishment is computed under article 7 and the applicable domestic provisions for the relevant period, with no deduction of expenditure under section 44D(b) and tax charged at 30 per cent under section 115A; section 44DA was held inapplicable for that assessment period. Case-Laws Income Tax Fri, 11 Aug 2006 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=65257