https://www.taxtmi.com/caselaws?id=210760 Distinct components of an offshore oil-related contract may be characterised separately for tax purposes. For the IOCL arrangement, mobilisation and demobilisation linked to use of marine spread and vessels were treated as royalty under the treaty, while the installation element was treated as fees for technical services, so the receipts were only partly taxable. For the L&T subcontract, surveys, design, procurement, transport and post-installation services were treated as services or facilities connected with mineral oil operations exceeding the treaty threshold, creating a permanent establishment in India and bringing the income within section 44BB rather than fees for technical services. Mobilisation and demobilisation receipts were also taxable under section 44BB. 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 Distinct components of an offshore oil-related contract may be characterised separately for tax purposes. For the IOCL arrangement, mobilisation and demobilisation linked to use of marine spread and vessels were treated as royalty under the treaty, while the installation element was treated as fees for technical services, so the receipts were only partly taxable. For the L&T subcontract, surveys, design, procurement, transport and post-installation services were treated as services or facilities connected with mineral oil operations exceeding the treaty threshold, creating a permanent establishment in India and bringing the income within section 44BB rather than fees for technical services. Mobilisation and demobilisation receipts were also taxable under section 44BB. Case-Laws Income Tax Wed, 15 Feb 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=210760