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    <title>2012 (10) TMI 759 - ITAT, DELHI</title>
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    <description>Supervisory receipts from erection, start-up, commissioning and training were treated as taxable in India as business profits or fees for technical services, because the assessee had only rendered supervision services, failed to establish eligibility for presumptive taxation under section 44BBB, and was found to have a permanent establishment in India. The article also notes that where the payer was obliged to deduct tax at source under section 195 and did so, interest under section 234B was not leviable for default in advance tax payment.</description>
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      <description>Supervisory receipts from erection, start-up, commissioning and training were treated as taxable in India as business profits or fees for technical services, because the assessee had only rendered supervision services, failed to establish eligibility for presumptive taxation under section 44BBB, and was found to have a permanent establishment in India. The article also notes that where the payer was obliged to deduct tax at source under section 195 and did so, interest under section 234B was not leviable for default in advance tax payment.</description>
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