https://www.taxtmi.com/caselaws?id=213352 Payments for architectural work by an Indian payer to a China-based recipient are discussed under the India-China tax treaty, with emphasis on whether the services fall within professional services and whether the recipient lacks a permanent establishment or fixed base in India. The note also addresses interest disallowance on borrowings allegedly used for advances to sister concerns, explaining that the governing test requires examination of commercial expediency, the source of funds, and the factual nexus between borrowed money and the advances before any disallowance is made. en-us Mon, 14 May 2012 00:00:00 +0530 Sat, 19 May 2012 06:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=213352 Payments for architectural work by an Indian payer to a China-based recipient are discussed under the India-China tax treaty, with emphasis on whether the services fall within professional services and whether the recipient lacks a permanent establishment or fixed base in India. The note also addresses interest disallowance on borrowings allegedly used for advances to sister concerns, explaining that the governing test requires examination of commercial expediency, the source of funds, and the factual nexus between borrowed money and the advances before any disallowance is made. Case-Laws Income Tax Mon, 14 May 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=213352