https://www.taxtmi.com/caselaws?id=75809 An architectural agreement was treated as a composite contract for design and consultancy services, so the consideration could not be split into separate sale and service components. The architect's services, including concept development, schematic designs, design development, construction documents, bidding assistance, and construction-phase consultancy, were regarded as fees for included services under Article 12 of the India-US DTAA, with section 115A applying as the lower rate. Reimbursements on actuals and pass-through payments to US consultants were excluded from taxable receipts, subject to verification, because they were not treated as chargeable income and no withholding was required on those amounts. en-us Thu, 18 Mar 2010 00:00:00 +0530 Mon, 16 Aug 2010 17:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=75809 An architectural agreement was treated as a composite contract for design and consultancy services, so the consideration could not be split into separate sale and service components. The architect's services, including concept development, schematic designs, design development, construction documents, bidding assistance, and construction-phase consultancy, were regarded as fees for included services under Article 12 of the India-US DTAA, with section 115A applying as the lower rate. Reimbursements on actuals and pass-through payments to US consultants were excluded from taxable receipts, subject to verification, because they were not treated as chargeable income and no withholding was required on those amounts. Case-Laws Income Tax Thu, 18 Mar 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=75809