https://www.taxtmi.com/caselaws?id=213698 Composite contract receipts were apportioned by the nature and place of performance of the services. Inspection and boroscoping carried out in India were taxable as fees for technical services, while overhauling performed in the United States was not taxable in India because it did not satisfy the make available requirement under Article 12 of the Indo-US DTAA. Modifications and replacement work accompanied by delivery of engineering designs, data and specifications were treated as making available technical knowledge and were taxable in India as fees for included services or royalty. Tax deduction at source under section 195 applied only to the portion of consideration found taxable in India. en-us Wed, 30 May 2012 00:00:00 +0530 Mon, 01 Jul 2013 11:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=213698 Composite contract receipts were apportioned by the nature and place of performance of the services. Inspection and boroscoping carried out in India were taxable as fees for technical services, while overhauling performed in the United States was not taxable in India because it did not satisfy the make available requirement under Article 12 of the Indo-US DTAA. Modifications and replacement work accompanied by delivery of engineering designs, data and specifications were treated as making available technical knowledge and were taxable in India as fees for included services or royalty. Tax deduction at source under section 195 applied only to the portion of consideration found taxable in India. Case-Laws Income Tax Wed, 30 May 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=213698