https://www.taxtmi.com/caselaws?id=233906 Taxability of receipts for technical documentation and engineering services was not finally decided because the record showed separate agreements and separate invoices for the year under appeal, and the treaty position and Supreme Court precedent on composite contracts and apportionment had not been fully examined. As the existing orders were insufficient to conclude whether the amounts were taxable as royalty or fee for technical services, the Tribunal sent the matter back for fresh adjudication. The Assessing Officer was directed to reconsider all relevant facts and legal authorities, leaving the taxability issue open. en-us Fri, 05 Apr 2013 00:00:00 +0530 Tue, 21 May 2013 08:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=233906 Taxability of receipts for technical documentation and engineering services was not finally decided because the record showed separate agreements and separate invoices for the year under appeal, and the treaty position and Supreme Court precedent on composite contracts and apportionment had not been fully examined. As the existing orders were insufficient to conclude whether the amounts were taxable as royalty or fee for technical services, the Tribunal sent the matter back for fresh adjudication. The Assessing Officer was directed to reconsider all relevant facts and legal authorities, leaving the taxability issue open. Case-Laws Income Tax Fri, 05 Apr 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=233906