https://www.taxtmi.com/highlights?id=4707 DTAA between India and Austria - subcontract - PE - That person can at best be said to render technical services or services 'in connection with' the mining activity undertaken by the original contractor - the revenues earned by the applicant are not taxable in accordance with section 44BB and are taxable only as fees for technical services. - AAR en-us Tue, 07 Aug 2012 08:34:34 +0530 Tue, 07 Aug 2012 08:34:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=4707 DTAA between India and Austria - subcontract - PE - That person can at best be said to render technical services or services 'in connection with' the mining activity undertaken by the original contractor - the revenues earned by the applicant are not taxable in accordance with section 44BB and are taxable only as fees for technical services. - AAR Highlights Income Tax Tue, 07 Aug 2012 08:34:34 +0530 https://www.taxtmi.com/highlights?id=4707