https://www.taxtmi.com/caselaws?id=418078 Reimbursements such as material and fuel recharge were treated as part of gross receipts for computing income under the presumptive scheme of section 44BB, so the assessee's challenge on that point failed. Interest on income-tax refund was found not to be effectively connected with the permanent establishment on either the asset test or the activity test, so it was taxed under Article 11 of the Indo-US DTAA rather than as business income attributable to the permanent establishment. Treaty protection under section 90(2) was applied because the treaty outcome was more beneficial. en-us Fri, 28 Jan 2022 00:00:00 +0530 Mon, 07 Feb 2022 22:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=418078 Reimbursements such as material and fuel recharge were treated as part of gross receipts for computing income under the presumptive scheme of section 44BB, so the assessee's challenge on that point failed. Interest on income-tax refund was found not to be effectively connected with the permanent establishment on either the asset test or the activity test, so it was taxed under Article 11 of the Indo-US DTAA rather than as business income attributable to the permanent establishment. Treaty protection under section 90(2) was applied because the treaty outcome was more beneficial. Case-Laws Income Tax Fri, 28 Jan 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=418078