https://www.taxtmi.com/caselaws?id=325317 Engineering, design, start-up and overall responsibility receipts were examined under section 9(1)(vii) and Article 12 of the India-US treaty. Because the services were largely performed outside India and did not make available technical knowledge, skill, know-how or technical design to the Indian customer, they did not qualify as fees for technical services or included services. The contract was treated as a composite offshore supply arrangement linked to equipment supply and start-up activity. In the absence of a permanent establishment in India, the receipts were characterised as business profits taxable only if attributable to such establishment, and no Indian tax liability arose on these facts. en-us Fri, 11 Mar 2016 00:00:00 +0530 Wed, 16 Mar 2016 10:18:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=325317 Engineering, design, start-up and overall responsibility receipts were examined under section 9(1)(vii) and Article 12 of the India-US treaty. Because the services were largely performed outside India and did not make available technical knowledge, skill, know-how or technical design to the Indian customer, they did not qualify as fees for technical services or included services. The contract was treated as a composite offshore supply arrangement linked to equipment supply and start-up activity. In the absence of a permanent establishment in India, the receipts were characterised as business profits taxable only if attributable to such establishment, and no Indian tax liability arose on these facts. Case-Laws Income Tax Fri, 11 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=325317