https://www.taxtmi.com/caselaws?id=3824 Project monitoring and supervision services did not amount to royalty under Article 12 of the India-Australia DTAA because the contract did not make technical knowledge, experience, skill or know-how available to GAIL for independent use. The receipts were therefore treated as business profits under Article 7. As the applicant carried on activities in India for more than six months and the supervisory functions constituted a permanent establishment under Article 5(2)(k), only the profits attributable to that Indian permanent establishment were taxable in India. en-us Wed, 30 Apr 2008 00:00:00 +0530 Sun, 27 Jul 2008 07:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=3824 Project monitoring and supervision services did not amount to royalty under Article 12 of the India-Australia DTAA because the contract did not make technical knowledge, experience, skill or know-how available to GAIL for independent use. The receipts were therefore treated as business profits under Article 7. As the applicant carried on activities in India for more than six months and the supervisory functions constituted a permanent establishment under Article 5(2)(k), only the profits attributable to that Indian permanent establishment were taxable in India. Case-Laws Income Tax Wed, 30 Apr 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=3824