https://www.taxtmi.com/caselaws?id=256683 Where a tax treaty covers business profits but contains no separate fees-for-technical-services provision, receipts from services rendered in the course of business are taxable in India only if attributable to a permanent establishment; domestic law cannot enlarge taxability contrary to the treaty. On that basis, the service receipt was treated as business profit and not taxable as fees for technical services because no permanent establishment in India was shown. Interest under section 234B was also held not leviable in the stated circumstances, following binding precedent. The section 234D aspect was left for verification at assessment stage. en-us Fri, 13 Feb 2015 00:00:00 +0530 Thu, 19 Feb 2015 11:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=256683 Where a tax treaty covers business profits but contains no separate fees-for-technical-services provision, receipts from services rendered in the course of business are taxable in India only if attributable to a permanent establishment; domestic law cannot enlarge taxability contrary to the treaty. On that basis, the service receipt was treated as business profit and not taxable as fees for technical services because no permanent establishment in India was shown. Interest under section 234B was also held not leviable in the stated circumstances, following binding precedent. The section 234D aspect was left for verification at assessment stage. Case-Laws Income Tax Fri, 13 Feb 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=256683