https://www.taxtmi.com/caselaws?id=177878 Consideration for executing a construction or installation project was held not to fall within fees for technical services under the India-France treaty, because Article 13 had to be read harmoniously with the business profits and permanent establishment articles. The contract was treated as a single pipeline installation project, and receipts arising from such execution were characterised as business profits under Article 7. As the project did not continue for more than six months, no permanent establishment arose under Article 5(3), so the receipts were not taxable in India. The domestic exclusion for construction, assembly, mining or similar projects in section 9(1)(vii) was also relied on. en-us Fri, 26 Sep 1997 00:00:00 +0530 Thu, 21 Jan 2016 11:52:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=177878 Consideration for executing a construction or installation project was held not to fall within fees for technical services under the India-France treaty, because Article 13 had to be read harmoniously with the business profits and permanent establishment articles. The contract was treated as a single pipeline installation project, and receipts arising from such execution were characterised as business profits under Article 7. As the project did not continue for more than six months, no permanent establishment arose under Article 5(3), so the receipts were not taxable in India. The domestic exclusion for construction, assembly, mining or similar projects in section 9(1)(vii) was also relied on. Case-Laws Income Tax Fri, 26 Sep 1997 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=177878