https://www.taxtmi.com/caselaws?id=284887 Underwriting commission was treated as fees for technical services under Article 12 of the DTAA because the services were characterised as managerial or consultancy in nature, and the permanent establishment inquiry under Article 5 became unnecessary for taxing the same income as business profits. Gains from transfer of debt securities were analysed under the special regime applicable to a foreign institutional investor and were treated as capital gains rather than business income. Interest under sections 234B and 234C was held not leviable because the income was subject to tax deduction at source, leaving no advance tax liability. en-us Fri, 17 Apr 2015 00:00:00 +0530 Mon, 16 Dec 2019 09:52:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=284887 Underwriting commission was treated as fees for technical services under Article 12 of the DTAA because the services were characterised as managerial or consultancy in nature, and the permanent establishment inquiry under Article 5 became unnecessary for taxing the same income as business profits. Gains from transfer of debt securities were analysed under the special regime applicable to a foreign institutional investor and were treated as capital gains rather than business income. Interest under sections 234B and 234C was held not leviable because the income was subject to tax deduction at source, leaving no advance tax liability. Case-Laws Income Tax Fri, 17 Apr 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=284887