https://www.taxtmi.com/caselaws?id=395724 Receipts from a detailed project implementation report and engineering services performed from outside India were not attributable to business profits in India because no permanent establishment was shown during the relevant period. The project office in India was set up later and was tied to proposed construction supervision that never materialised, while the record did not establish actual activity through a fixed place or personnel in India, nor the conditions for a construction or supervisory permanent establishment under the treaty threshold. The income was therefore taxable as fees for technical services under Article 13(4) of the India-Spain DTAA, not as business profits attributable to a permanent establishment. en-us Fri, 29 May 2020 00:00:00 +0530 Thu, 04 Jun 2020 05:30:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=395724 Receipts from a detailed project implementation report and engineering services performed from outside India were not attributable to business profits in India because no permanent establishment was shown during the relevant period. The project office in India was set up later and was tied to proposed construction supervision that never materialised, while the record did not establish actual activity through a fixed place or personnel in India, nor the conditions for a construction or supervisory permanent establishment under the treaty threshold. The income was therefore taxable as fees for technical services under Article 13(4) of the India-Spain DTAA, not as business profits attributable to a permanent establishment. Case-Laws Income Tax Fri, 29 May 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=395724