https://www.taxtmi.com/caselaws?id=210760 The ruling determined that part of the consideration under the IOCL contract qualifies as 'Fees for Technical Services' under section 9(1)(vii) of the Income-tax Act and Article 12 of the India-Singapore Double Tax Avoidance Agreement. Additionally, part of the consideration under the same contract was classified as 'Royalty' under the relevant provisions. The applicant was found to have a Permanent Establishment in India concerning the contract with L&T. The income derived from both contracts was deemed taxable in India, with specific computation under section 44BB of the Act for the L&T contract. Furthermore, the mobilization and demobilization revenues were held to be taxable in India under the same section. en-us Wed, 15 Feb 2012 00:00:00 +0530 Tue, 29 May 2012 15:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=210760 The ruling determined that part of the consideration under the IOCL contract qualifies as 'Fees for Technical Services' under section 9(1)(vii) of the Income-tax Act and Article 12 of the India-Singapore Double Tax Avoidance Agreement. Additionally, part of the consideration under the same contract was classified as 'Royalty' under the relevant provisions. The applicant was found to have a Permanent Establishment in India concerning the contract with L&T. The income derived from both contracts was deemed taxable in India, with specific computation under section 44BB of the Act for the L&T contract. Furthermore, the mobilization and demobilization revenues were held to be taxable in India under the same section. Case-Laws Income Tax Wed, 15 Feb 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=210760