https://www.taxtmi.com/caselaws?id=186113 Supervision, erection and commissioning receipts did not qualify for presumptive taxation under section 44BBB because the activities were limited to supervision simpliciter and were not shown to constitute erection, assembly, testing or commissioning business. A permanent establishment in India was sustained, and the receipts were treated as fees for technical services under the applicable treaty provisions read with sections 44D and 115A. Interest under section 234B was not leviable where the payer was required to deduct tax at source under section 195 and had deducted it; the payee was therefore not liable for advance-tax interest on that income. The substantive taxability challenge failed, with relief confined to interest. 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 Supervision, erection and commissioning receipts did not qualify for presumptive taxation under section 44BBB because the activities were limited to supervision simpliciter and were not shown to constitute erection, assembly, testing or commissioning business. A permanent establishment in India was sustained, and the receipts were treated as fees for technical services under the applicable treaty provisions read with sections 44D and 115A. Interest under section 234B was not leviable where the payer was required to deduct tax at source under section 195 and had deducted it; the payee was therefore not liable for advance-tax interest on that income. The substantive taxability challenge failed, with relief confined to interest. Case-Laws Income Tax Mon, 09 May 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=186113