https://www.taxtmi.com/caselaws?id=173242 Technical and consultancy receipts received by a foreign company were treated as fees for technical services, not as income governed by the presumptive regime in section 44BB, because the agreements related to technical work and not to mining or prospecting operations. The article explains that such receipts fall within the special charging framework for fees for technical services and are not protected as business income under section 44BB where the statutory exclusions apply. It also notes that under the UK treaty, article 13 governs fees for technical services, the services made available technical knowledge and know-how, and the more beneficial treaty rate prevailed under section 90(2), resulting in taxability at twenty per cent of the gross amount. 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 Technical and consultancy receipts received by a foreign company were treated as fees for technical services, not as income governed by the presumptive regime in section 44BB, because the agreements related to technical work and not to mining or prospecting operations. The article explains that such receipts fall within the special charging framework for fees for technical services and are not protected as business income under section 44BB where the statutory exclusions apply. It also notes that under the UK treaty, article 13 governs fees for technical services, the services made available technical knowledge and know-how, and the more beneficial treaty rate prevailed under section 90(2), resulting in taxability at twenty per cent of the gross amount. Case-Laws Income Tax Fri, 08 Sep 1995 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=173242