https://www.taxtmi.com/caselaws?id=360383 Composite operation and maintenance receipts involving advisory support, technical guidance, training and project-related services were characterised as business income under the DTAA's business profits article, rather than fees for technical services. A contractual payment to ETPL for customs clearance and transportation services was treated as a crystallised business liability and allowed as expenditure. The turnkey power project receipts from supervision, erection and maintenance were brought within the special computation rule for foreign companies under section 44BBB, while supervision fee remained taxable under Article 12(2) as fees for technical services. Interest under section 234B was held not leviable on the non-resident assessee. en-us Wed, 09 May 2018 00:00:00 +0530 Wed, 16 May 2018 06:44:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=360383 Composite operation and maintenance receipts involving advisory support, technical guidance, training and project-related services were characterised as business income under the DTAA's business profits article, rather than fees for technical services. A contractual payment to ETPL for customs clearance and transportation services was treated as a crystallised business liability and allowed as expenditure. The turnkey power project receipts from supervision, erection and maintenance were brought within the special computation rule for foreign companies under section 44BBB, while supervision fee remained taxable under Article 12(2) as fees for technical services. Interest under section 234B was held not leviable on the non-resident assessee. Case-Laws Income Tax Wed, 09 May 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=360383