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    <title>2019 (4) TMI 1428 - ITAT DELHI</title>
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    <description>Receipts earned by a consortium member from project execution were treated as business profits attributable to its Indian permanent establishment, because the contracts showed only allocation of work within the joint venture and no separate transfer of technical know-how; the attempted characterisation as royalty or fees for technical services was rejected. Transit office facility expenses were not finally allowed on merits and remained dependent on further confirmation of payment evidence. Interest under section 234B was held not chargeable to the non-resident assessee where tax was deductible at source, following binding jurisdictional precedent.</description>
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      <description>Receipts earned by a consortium member from project execution were treated as business profits attributable to its Indian permanent establishment, because the contracts showed only allocation of work within the joint venture and no separate transfer of technical know-how; the attempted characterisation as royalty or fees for technical services was rejected. Transit office facility expenses were not finally allowed on merits and remained dependent on further confirmation of payment evidence. Interest under section 234B was held not chargeable to the non-resident assessee where tax was deductible at source, following binding jurisdictional precedent.</description>
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