https://www.taxtmi.com/caselaws?id=173063 A composite contract for design, manufacture, supply, testing and commissioning of passenger rolling stock was held divisible for tax purposes where the pricing structure identified separate components. Services such as project management, interface coordination, design submission, training and supervision were examined to determine whether they were incidental to supply or independent technical services. Cost centres A and B were treated as integral to the supply contract, while cost centres G and J were found to be separately identifiable service obligations. The amounts attributable to G and J were therefore characterised as fees for technical services, and not as business profits under the treaty's general article. en-us Fri, 26 Aug 2005 00:00:00 +0530 Fri, 23 Oct 2015 16:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=173063 A composite contract for design, manufacture, supply, testing and commissioning of passenger rolling stock was held divisible for tax purposes where the pricing structure identified separate components. Services such as project management, interface coordination, design submission, training and supervision were examined to determine whether they were incidental to supply or independent technical services. Cost centres A and B were treated as integral to the supply contract, while cost centres G and J were found to be separately identifiable service obligations. The amounts attributable to G and J were therefore characterised as fees for technical services, and not as business profits under the treaty's general article. Case-Laws Income Tax Fri, 26 Aug 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=173063