https://www.taxtmi.com/caselaws?id=65312 Treaty exemption for expatriate technicians was denied because the remuneration was borne by the Indian permanent establishment: the technicians' salary was treated as a direct business outgoing attributable to the PE, so article 16(2)(c) of the India-USA DTAA and corresponding treaty provisions with Australia and Indonesia did not apply. Off-period salary was taxable in India as it remained connected with services rendered in India under section 9(1)(ii) and the relevant Explanation. Boarding and lodging on the rig was not a taxable perquisite under section 17(2)(iii). Interest under section 234B was also not leviable on the facts. The result was partial relief to the assessees. en-us Mon, 26 Jul 2004 00:00:00 +0530 Mon, 14 Feb 2011 18:23:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=65312 Treaty exemption for expatriate technicians was denied because the remuneration was borne by the Indian permanent establishment: the technicians' salary was treated as a direct business outgoing attributable to the PE, so article 16(2)(c) of the India-USA DTAA and corresponding treaty provisions with Australia and Indonesia did not apply. Off-period salary was taxable in India as it remained connected with services rendered in India under section 9(1)(ii) and the relevant Explanation. Boarding and lodging on the rig was not a taxable perquisite under section 17(2)(iii). Interest under section 234B was also not leviable on the facts. The result was partial relief to the assessees. Case-Laws Income Tax Mon, 26 Jul 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=65312