https://www.taxtmi.com/caselaws?id=213970 The Tribunal notes that project revenue recognition may follow the percentage of completion method where the facts are identical to the assessee's earlier year and the prior view is applied. Offshore supply receipts for equipment supplied and paid for outside India are stated not to accrue or arise in India and are therefore not taxable in India. Project management receipts are treated as fees for technical services under domestic law, but the more beneficial India-Japan DTAA applies, so the receipts are to be computed as business profits attributable to the permanent establishment under the treaty framework after verification of allowable expenses. Interest under sections 234B and 234C is not chargeable where tax was deductible at source from payments to the non-resident. en-us Tue, 03 Apr 2012 00:00:00 +0530 Wed, 13 Jun 2012 14:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=213970 The Tribunal notes that project revenue recognition may follow the percentage of completion method where the facts are identical to the assessee's earlier year and the prior view is applied. Offshore supply receipts for equipment supplied and paid for outside India are stated not to accrue or arise in India and are therefore not taxable in India. Project management receipts are treated as fees for technical services under domestic law, but the more beneficial India-Japan DTAA applies, so the receipts are to be computed as business profits attributable to the permanent establishment under the treaty framework after verification of allowable expenses. Interest under sections 234B and 234C is not chargeable where tax was deductible at source from payments to the non-resident. Case-Laws Income Tax Tue, 03 Apr 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=213970