https://www.taxtmi.com/caselaws?id=208302 Receipts for evaluation and related technical work, including mapping, drilling, testing, feasibility studies and report preparation, were treated as fees for technical services rather than as payments for a composite business activity, and the construction/mining exclusion was held inapplicable. Where the non-resident had a permanent establishment in India, Article 7 of the India-Australia DTAA governed the attributable business profits, while Article 7(3) preserved deductions under Indian tax law subject to treaty limits. On that basis, Section 44D applied to the foreign company's fees for technical services income, restricting ordinary deductions to the extent permitted by the statute. en-us Wed, 04 Jan 2012 00:00:00 +0530 Thu, 15 Jan 2026 13:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=208302 Receipts for evaluation and related technical work, including mapping, drilling, testing, feasibility studies and report preparation, were treated as fees for technical services rather than as payments for a composite business activity, and the construction/mining exclusion was held inapplicable. Where the non-resident had a permanent establishment in India, Article 7 of the India-Australia DTAA governed the attributable business profits, while Article 7(3) preserved deductions under Indian tax law subject to treaty limits. On that basis, Section 44D applied to the foreign company's fees for technical services income, restricting ordinary deductions to the extent permitted by the statute. Case-Laws Income Tax Wed, 04 Jan 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=208302