https://www.taxtmi.com/caselaws?id=332087 Proposal costs charged by a group company were treated as deductible business expenditure under section 37 because they were shown to have been incurred for the project office and actually paid to the group company. Payments to non-resident service providers and the group company were not taxed as fees for technical services because the services were administrative and support in nature and did not satisfy the treaty "make available" test under Article 13(4) of the India-UK DTAA. A contractual delay-related price reduction was allowed as a deduction on the basis of actual invoices and accrual, being an adjustment to project receipts rather than a penal levy. en-us Wed, 10 Aug 2016 00:00:00 +0530 Tue, 31 Jan 2017 18:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=332087 Proposal costs charged by a group company were treated as deductible business expenditure under section 37 because they were shown to have been incurred for the project office and actually paid to the group company. Payments to non-resident service providers and the group company were not taxed as fees for technical services because the services were administrative and support in nature and did not satisfy the treaty "make available" test under Article 13(4) of the India-UK DTAA. A contractual delay-related price reduction was allowed as a deduction on the basis of actual invoices and accrual, being an adjustment to project receipts rather than a penal levy. Case-Laws Income Tax Wed, 10 Aug 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=332087