https://www.taxtmi.com/caselaws?id=186113 Receipts from supervision, erection and commissioning were examined for taxability under the Income-tax Act and the applicable DTAA. On the stated facts, the assessee was found to have rendered only supervision simpliciter and not to have shown activities amounting to erection, assembly, testing or commissioning, so section 44BBB did not apply; the note also records that the Indian permanent establishment finding was upheld and the receipts were treated as fees for technical services under Article 7 read with sections 44D and 115A. On interest, where tax was deductible at source and had in fact been deducted, section 234B interest was held not leviable. en-us Mon, 09 May 2011 00:00:00 +0530 Wed, 07 Sep 2016 16:31:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=186113 Receipts from supervision, erection and commissioning were examined for taxability under the Income-tax Act and the applicable DTAA. On the stated facts, the assessee was found to have rendered only supervision simpliciter and not to have shown activities amounting to erection, assembly, testing or commissioning, so section 44BBB did not apply; the note also records that the Indian permanent establishment finding was upheld and the receipts were treated as fees for technical services under Article 7 read with sections 44D and 115A. On interest, where tax was deductible at source and had in fact been deducted, section 234B interest was held not leviable. Case-Laws Income Tax Mon, 09 May 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=186113