https://www.taxtmi.com/caselaws?id=173242 Consulting receipts of a foreign company for technical and consultancy services were characterised as fees for technical services rather than income eligible for the presumptive mineral-oil regime. That regime did not apply because the services were not undertaken for mining or a similar project by the recipient, while the special provisions governing technical-service fees applied. Under the India-UK tax treaty, the services made available technical knowledge, experience, skill and know-how, bringing the receipts within the treaty provision for fees for technical services. The business-profits provision did not apply in the absence of a permanent establishment. The more beneficial treaty rate applied over the domestic rate. en-us Fri, 08 Sep 1995 00:00:00 +0530 Fri, 23 Oct 2015 17:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=173242 Consulting receipts of a foreign company for technical and consultancy services were characterised as fees for technical services rather than income eligible for the presumptive mineral-oil regime. That regime did not apply because the services were not undertaken for mining or a similar project by the recipient, while the special provisions governing technical-service fees applied. Under the India-UK tax treaty, the services made available technical knowledge, experience, skill and know-how, bringing the receipts within the treaty provision for fees for technical services. The business-profits provision did not apply in the absence of a permanent establishment. The more beneficial treaty rate applied over the domestic rate. Case-Laws Income Tax Fri, 08 Sep 1995 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=173242