https://www.taxtmi.com/caselaws?id=326203 The court held that the consideration for services rendered by the Assessee was not "fees for technical services," favoring the Assessee over the Revenue. Regarding taxability under Section 44BB, the court ruled that if the income was within Section 44DA(1), it would be taxable under Section 44BB(1). However, if considered "fees for technical services," the AO needed to determine if the Assessee had a Permanent Establishment in India. The matter was remitted to the AO for assessment under Section 44BB of the Act, setting aside the previous orders. en-us Fri, 08 Apr 2016 00:00:00 +0530 Wed, 04 May 2016 14:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=326203 The court held that the consideration for services rendered by the Assessee was not "fees for technical services," favoring the Assessee over the Revenue. Regarding taxability under Section 44BB, the court ruled that if the income was within Section 44DA(1), it would be taxable under Section 44BB(1). However, if considered "fees for technical services," the AO needed to determine if the Assessee had a Permanent Establishment in India. The matter was remitted to the AO for assessment under Section 44BB of the Act, setting aside the previous orders. Case-Laws Income Tax Fri, 08 Apr 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=326203