https://www.taxtmi.com/caselaws?id=122442 Receipts from composite technical and evaluation services performed through a project office and admitted permanent establishment in India were taxable as business profits attributable to the PE under Article 7 of the DTAA, not as fee for technical services under section 9(1)(vii). Because the assessee elected DTAA treatment, the special gross-basis regime for foreign companies under sections 44D and 115A did not apply. The income therefore had to be computed on net basis under the regular provisions applicable to the PE as an independent enterprise, with ordinary deductions available under the Act. en-us Fri, 19 Mar 2010 00:00:00 +0530 Mon, 13 Aug 2012 16:38:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=122442 Receipts from composite technical and evaluation services performed through a project office and admitted permanent establishment in India were taxable as business profits attributable to the PE under Article 7 of the DTAA, not as fee for technical services under section 9(1)(vii). Because the assessee elected DTAA treatment, the special gross-basis regime for foreign companies under sections 44D and 115A did not apply. The income therefore had to be computed on net basis under the regular provisions applicable to the PE as an independent enterprise, with ordinary deductions available under the Act. Case-Laws Income Tax Fri, 19 Mar 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=122442