https://www.taxtmi.com/caselaws?id=126777 Contributions received by an implementing agency under an aid-funded project were treated as cost-sharing amounts, not commercial consideration for services rendered. The payments were used to meet local project expenses through a common project account, and therefore did not constitute income chargeable to tax under the Income-tax Act, 1961. Although technical and consultancy assistance was provided, the sums were not consideration for those services and so did not fall within fees for technical services under section 9(1)(vii) or the corresponding treaty provision. The operative principle is that a payment made only toward shared project expenditure, rather than as remuneration, is outside both income and FTS treatment. en-us Fri, 17 May 1996 00:00:00 +0530 Thu, 10 Jan 2013 18:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=126777 Contributions received by an implementing agency under an aid-funded project were treated as cost-sharing amounts, not commercial consideration for services rendered. The payments were used to meet local project expenses through a common project account, and therefore did not constitute income chargeable to tax under the Income-tax Act, 1961. Although technical and consultancy assistance was provided, the sums were not consideration for those services and so did not fall within fees for technical services under section 9(1)(vii) or the corresponding treaty provision. The operative principle is that a payment made only toward shared project expenditure, rather than as remuneration, is outside both income and FTS treatment. Case-Laws Income Tax Fri, 17 May 1996 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=126777