https://www.taxtmi.com/caselaws?id=179706 Supervision charges earned by a foreign company on a turnkey power project were treated as fees for technical services because the evidence showed only supervision of erection, testing and commissioning work, and not the company's own construction, assembly, erection or commissioning activity. On that basis, the receipts were held outside section 44BBB and taxable under the relevant DTAA and domestic provisions. Interest under section 234B was not leviable where the receipts were subject to tax deduction at source under section 195, so that levy was deleted. The taxability issue was upheld, while the interest issue was decided in favour of the assessee. en-us Fri, 05 Mar 2010 00:00:00 +0530 Mon, 09 Oct 2023 17:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=179706 Supervision charges earned by a foreign company on a turnkey power project were treated as fees for technical services because the evidence showed only supervision of erection, testing and commissioning work, and not the company's own construction, assembly, erection or commissioning activity. On that basis, the receipts were held outside section 44BBB and taxable under the relevant DTAA and domestic provisions. Interest under section 234B was not leviable where the receipts were subject to tax deduction at source under section 195, so that levy was deleted. The taxability issue was upheld, while the interest issue was decided in favour of the assessee. Case-Laws Income Tax Fri, 05 Mar 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=179706