https://www.taxtmi.com/caselaws?id=299356 Where a Singapore resident operated through a permanent establishment in India and earned receipts from collection and dissemination of market information, the income was treated under the India-Singapore DTAA as business profits rather than fees for technical services. On that treaty-based characterization, the domestic gross-taxation regime and the restrictions in section 44D read with section 115A could not be applied. The proper basis of assessment was attribution of business profits to the permanent establishment under Article 7(3) of the DTAA, subject to the treaty's limitations. en-us Thu, 18 Feb 2010 00:00:00 +0530 Fri, 10 Dec 2021 17:26:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=299356 Where a Singapore resident operated through a permanent establishment in India and earned receipts from collection and dissemination of market information, the income was treated under the India-Singapore DTAA as business profits rather than fees for technical services. On that treaty-based characterization, the domestic gross-taxation regime and the restrictions in section 44D read with section 115A could not be applied. The proper basis of assessment was attribution of business profits to the permanent establishment under Article 7(3) of the DTAA, subject to the treaty's limitations. Case-Laws Income Tax Thu, 18 Feb 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=299356