https://www.taxtmi.com/caselaws?id=215476 Services carried on in India in connection with prospecting and exploration of mineral oil created a deemed permanent establishment under the India-Austria treaty, and the contract income was attributable to that establishment. Seismic data acquisition and processing performed by a sub-contractor were treated as fees for technical services rather than income eligible for section 44BB, because the recipient did not itself undertake the mining project within the treaty and statutory exception. As the receipts were chargeable as technical services income, tax deduction at source was required at the rate determined in the ruling. en-us Tue, 31 Jul 2012 00:00:00 +0530 Tue, 11 Sep 2012 15:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=215476 Services carried on in India in connection with prospecting and exploration of mineral oil created a deemed permanent establishment under the India-Austria treaty, and the contract income was attributable to that establishment. Seismic data acquisition and processing performed by a sub-contractor were treated as fees for technical services rather than income eligible for section 44BB, because the recipient did not itself undertake the mining project within the treaty and statutory exception. As the receipts were chargeable as technical services income, tax deduction at source was required at the rate determined in the ruling. Case-Laws Income Tax Tue, 31 Jul 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=215476