https://www.taxtmi.com/caselaws?id=244471 Receipts from pipeline project work were characterised as fees for technical services because the assessee's actual role was confined to design and engineering, review of procedures, preparation of welding procedures, and deputation of experts for site review and technical supervision. The available material did not show execution of full construction work, so the construction-project exclusion in Explanation 2 to Section 9(1)(vii) of the Income-tax Act, 1961 did not apply. On that basis, the receipts remained taxable under Section 9(1)(vii) and the rate under Section 115A applied. The permanent establishment and business profits question was treated as unnecessary once this domestic tax characterisation was reached. en-us Fri, 14 Feb 2014 00:00:00 +0530 Thu, 27 Feb 2014 08:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=244471 Receipts from pipeline project work were characterised as fees for technical services because the assessee's actual role was confined to design and engineering, review of procedures, preparation of welding procedures, and deputation of experts for site review and technical supervision. The available material did not show execution of full construction work, so the construction-project exclusion in Explanation 2 to Section 9(1)(vii) of the Income-tax Act, 1961 did not apply. On that basis, the receipts remained taxable under Section 9(1)(vii) and the rate under Section 115A applied. The permanent establishment and business profits question was treated as unnecessary once this domestic tax characterisation was reached. Case-Laws Income Tax Fri, 14 Feb 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=244471