https://www.taxtmi.com/caselaws?id=401460 Under the Indo-Sweden treaty, intermediary services such as marketing, sales and project management were treated as managerial or administrative support and not as fee for technical services because they did not make technical knowledge or skill available for independent future use. The treaty's most favoured nation benefit was applied, and the receipts were therefore outside the fee for technical services charge. On the PE issue, offshore supplies under contract BS-02 were made from outside India and only income attributable to operations carried out in India can be taxed in India. The alleged PE was not sustained on the existing record, subject only to limited verification of whether any employee had been seconded to India. en-us Fri, 27 Nov 2020 00:00:00 +0530 Tue, 08 Dec 2020 11:42:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=401460 Under the Indo-Sweden treaty, intermediary services such as marketing, sales and project management were treated as managerial or administrative support and not as fee for technical services because they did not make technical knowledge or skill available for independent future use. The treaty's most favoured nation benefit was applied, and the receipts were therefore outside the fee for technical services charge. On the PE issue, offshore supplies under contract BS-02 were made from outside India and only income attributable to operations carried out in India can be taxed in India. The alleged PE was not sustained on the existing record, subject only to limited verification of whether any employee had been seconded to India. Case-Laws Income Tax Fri, 27 Nov 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=401460