https://www.taxtmi.com/caselaws?id=126756 Procurement fees for arranging purchases of materials for plant fabrication are characterised as commercial profits, rather than royalty or fees for technical services, where the service does not impart technical know-how, industrial experience or consultancy. Under the applicable tax treaty, such profits are not taxable in India without a permanent establishment, with treaty provisions prevailing over domestic law under section 90(2). Flat-rate assessment on gross receipts leaves no separate basis for deduction of specified tax-representation expenses. Income subject to tax deduction at source does not create advance-tax liability for related interest purposes. Contractual amounts accrue when raised under the agreement unless shown to have become irrecoverable during the relevant year. en-us Fri, 24 Jan 1997 00:00:00 +0530 Mon, 31 Dec 2012 11:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=126756 Procurement fees for arranging purchases of materials for plant fabrication are characterised as commercial profits, rather than royalty or fees for technical services, where the service does not impart technical know-how, industrial experience or consultancy. Under the applicable tax treaty, such profits are not taxable in India without a permanent establishment, with treaty provisions prevailing over domestic law under section 90(2). Flat-rate assessment on gross receipts leaves no separate basis for deduction of specified tax-representation expenses. Income subject to tax deduction at source does not create advance-tax liability for related interest purposes. Contractual amounts accrue when raised under the agreement unless shown to have become irrecoverable during the relevant year. Case-Laws Income Tax Fri, 24 Jan 1997 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=126756