https://www.taxtmi.com/caselaws?id=252337 Supervisory, erection and commissioning receipts from a foreign enterprise were treated as fees for technical services under Article 12 of the India-Germany DTAA, because deputation of technicians to client sites did not create a fixed place permanent establishment and the conditions for shifting the income to business profits under Article 5 read with Article 7 were not met. Reopening under section 147 was held unsustainable because the case did not involve understatement of income or excessive relief within the scope of Explanation 2(b). Duplicate receipt verification was remitted for factual reconciliation, interest under sections 234A, 234B and 234C was to be recomputed, and consequential demand issues were to be modified accordingly. en-us Fri, 27 Jun 2014 00:00:00 +0530 Fri, 13 Mar 2015 14:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=252337 Supervisory, erection and commissioning receipts from a foreign enterprise were treated as fees for technical services under Article 12 of the India-Germany DTAA, because deputation of technicians to client sites did not create a fixed place permanent establishment and the conditions for shifting the income to business profits under Article 5 read with Article 7 were not met. Reopening under section 147 was held unsustainable because the case did not involve understatement of income or excessive relief within the scope of Explanation 2(b). Duplicate receipt verification was remitted for factual reconciliation, interest under sections 234A, 234B and 234C was to be recomputed, and consequential demand issues were to be modified accordingly. Case-Laws Income Tax Fri, 27 Jun 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=252337