https://www.taxtmi.com/caselaws?id=180168 Under the India-France treaty, the applicant was treated as a French resident with a permanent establishment in India because the project offices constituted a fixed place of business used to manage and oversee the contract work. Receipts under the project agreements were held to fall within royalty and fees for technical services, but amounts effectively connected with the permanent establishment could be taxed as business profits. The applicant remained the beneficial owner of the receipts, while payments by the permanent establishment to head office or foreign suppliers were not mere reimbursements and did not trigger Indian withholding on the facts. Profit attribution was confined to Indian operations, and section 115A applied only to the statutory royalty and technical-fee component, not to the construction or assembly element. en-us Wed, 23 Aug 1995 00:00:00 +0530 Fri, 18 Mar 2016 10:42:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=180168 Under the India-France treaty, the applicant was treated as a French resident with a permanent establishment in India because the project offices constituted a fixed place of business used to manage and oversee the contract work. Receipts under the project agreements were held to fall within royalty and fees for technical services, but amounts effectively connected with the permanent establishment could be taxed as business profits. The applicant remained the beneficial owner of the receipts, while payments by the permanent establishment to head office or foreign suppliers were not mere reimbursements and did not trigger Indian withholding on the facts. Profit attribution was confined to Indian operations, and section 115A applied only to the statutory royalty and technical-fee component, not to the construction or assembly element. Case-Laws Income Tax Wed, 23 Aug 1995 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=180168