https://www.taxtmi.com/caselaws?id=122991 Interest income and insurance receipts from fixed deposits maintained as margin for letters of credit and guarantees were treated as business income because the deposits had a direct commercial nexus with execution of the project business. Employee remuneration and welfare costs allocated to the Indian project were held outside the cap on head office expenditure because they were project-specific and supported by time sheets, ERP records and audit verification. Procurement-related payments were not fees for technical services, as they were commercial sourcing and coordination services rendered outside India with no Indian tax nexus, so withholding disallowance did not arise. Cash salary and site-related payments at a remote project location were covered by Rule 6DD and not disallowed under the cash payment restriction. en-us Wed, 10 Nov 2010 00:00:00 +0530 Fri, 11 Aug 2023 18:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=122991 Interest income and insurance receipts from fixed deposits maintained as margin for letters of credit and guarantees were treated as business income because the deposits had a direct commercial nexus with execution of the project business. Employee remuneration and welfare costs allocated to the Indian project were held outside the cap on head office expenditure because they were project-specific and supported by time sheets, ERP records and audit verification. Procurement-related payments were not fees for technical services, as they were commercial sourcing and coordination services rendered outside India with no Indian tax nexus, so withholding disallowance did not arise. Cash salary and site-related payments at a remote project location were covered by Rule 6DD and not disallowed under the cash payment restriction. Case-Laws Income Tax Wed, 10 Nov 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=122991