https://www.taxtmi.com/caselaws?id=277867 Receipts from O&M and project activities under a power-plant works contract were treated as business income on a net basis, not fees for technical services, because the treaty's make-available requirement was not met. Interest on foreign bank accounts, along with related credits such as write-backs, foreign exchange fluctuation and similar items, was treated as not taxable in India to the extent arising outside India under the treaty source rule. Carry forward and set-off of business losses and unabsorbed depreciation remained available under the Act. Interest under section 234B was not chargeable where the foreign company's income was subject to withholding tax under section 195. en-us Fri, 04 May 2012 00:00:00 +0530 Thu, 27 Dec 2018 15:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=277867 Receipts from O&M and project activities under a power-plant works contract were treated as business income on a net basis, not fees for technical services, because the treaty's make-available requirement was not met. Interest on foreign bank accounts, along with related credits such as write-backs, foreign exchange fluctuation and similar items, was treated as not taxable in India to the extent arising outside India under the treaty source rule. Carry forward and set-off of business losses and unabsorbed depreciation remained available under the Act. Interest under section 234B was not chargeable where the foreign company's income was subject to withholding tax under section 195. Case-Laws Income Tax Fri, 04 May 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=277867