https://www.taxtmi.com/caselaws?id=205584 Technical and consultancy services involving preparation and transfer of drawings, reports and designs for an Indian project were held to fall within Article 12(4)(b) of the India-Canada tax treaty. The clause was read disjunctively, so development and transfer of a technical plan or technical design is independently covered and does not require the recipient to be enabled to apply the knowledge in future projects. The receipts were therefore taxable as fees for included services at the treaty rate. The separate contention on interest under section 234B did not survive, as it had already been decided against the Revenue in an earlier binding ruling. en-us Wed, 22 Sep 2010 00:00:00 +0530 Mon, 26 Mar 2012 14:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=205584 Technical and consultancy services involving preparation and transfer of drawings, reports and designs for an Indian project were held to fall within Article 12(4)(b) of the India-Canada tax treaty. The clause was read disjunctively, so development and transfer of a technical plan or technical design is independently covered and does not require the recipient to be enabled to apply the knowledge in future projects. The receipts were therefore taxable as fees for included services at the treaty rate. The separate contention on interest under section 234B did not survive, as it had already been decided against the Revenue in an earlier binding ruling. Case-Laws Income Tax Wed, 22 Sep 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=205584