https://www.taxtmi.com/caselaws?id=362818 A non-resident's receipts for work performed outside India were held outside Indian taxability where it had no business operations or permanent establishment in India under the applicable treaty. The income could not be taxed merely because the contract was connected with India, and treaty protection prevailed over domestic charging provisions, so section 9(1)(i) and the alternative resort to section 44BB failed. Receipts for reserve certification services were also not taxable as fees for technical services because the services were rendered outside India and did not make available technical knowledge, skill, or know-how. In the absence of a permanent establishment, the amounts could not be taxed as business profits, and section 44BB was again inapplicable. en-us Fri, 29 Jun 2018 00:00:00 +0530 Wed, 04 Jul 2018 09:27:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=362818 A non-resident's receipts for work performed outside India were held outside Indian taxability where it had no business operations or permanent establishment in India under the applicable treaty. The income could not be taxed merely because the contract was connected with India, and treaty protection prevailed over domestic charging provisions, so section 9(1)(i) and the alternative resort to section 44BB failed. Receipts for reserve certification services were also not taxable as fees for technical services because the services were rendered outside India and did not make available technical knowledge, skill, or know-how. In the absence of a permanent establishment, the amounts could not be taxed as business profits, and section 44BB was again inapplicable. Case-Laws Income Tax Fri, 29 Jun 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=362818