https://www.taxtmi.com/caselaws?id=354208 A foreign enterprise was found to have a fixed place permanent establishment in India because it had space at its disposal at the project venue, including storage and working space, and carried on continuous on-site operations for preparation, execution, maintenance and dismantling. The lighting and searchlight receipts were held not to be royalty or fees for included services because the customer received the turnkey output, not the underlying know-how or technical knowledge on a make available basis. As the permanent establishment existed, the project income was taxable in India as business profits attributable to that PE under the treaty and also fell within section 9(1)(i). en-us Wed, 08 Nov 2017 00:00:00 +0530 Sat, 24 Feb 2018 14:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=354208 A foreign enterprise was found to have a fixed place permanent establishment in India because it had space at its disposal at the project venue, including storage and working space, and carried on continuous on-site operations for preparation, execution, maintenance and dismantling. The lighting and searchlight receipts were held not to be royalty or fees for included services because the customer received the turnkey output, not the underlying know-how or technical knowledge on a make available basis. As the permanent establishment existed, the project income was taxable in India as business profits attributable to that PE under the treaty and also fell within section 9(1)(i). Case-Laws Income Tax Wed, 08 Nov 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=354208