https://www.taxtmi.com/caselaws?id=6573 Payments for managerial, technical, engineering and related services were treated as consideration for fees for technical services, not a mere reimbursement of costs, even where charged at actual cost without mark-up; the payer was therefore required to withhold tax under section 195(1) at the lower of the Act or treaty rate. In computing income from such fees under section 44D read with section 115A, no implied option could be read in to adopt net-basis taxation or claim deductions under sections 28 to 44C, because section 44D is a special foreign-company provision that mandates gross-basis computation and cannot be expanded by analogy to a different presumptive-taxation context. en-us Mon, 06 Dec 2004 00:00:00 +0530 Thu, 14 Jul 2016 10:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6573 Payments for managerial, technical, engineering and related services were treated as consideration for fees for technical services, not a mere reimbursement of costs, even where charged at actual cost without mark-up; the payer was therefore required to withhold tax under section 195(1) at the lower of the Act or treaty rate. In computing income from such fees under section 44D read with section 115A, no implied option could be read in to adopt net-basis taxation or claim deductions under sections 28 to 44C, because section 44D is a special foreign-company provision that mandates gross-basis computation and cannot be expanded by analogy to a different presumptive-taxation context. Case-Laws Income Tax Mon, 06 Dec 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6573