https://www.taxtmi.com/caselaws?id=28470 A double taxation agreement was treated as an additional remedial framework and not a substitute for domestic remedies under the Income-tax Act. The agreement prevailed over section 9(1)(i) to the extent of any inconsistency, so foreign business profits were taxable in India only if attributable to a permanent establishment. On the facts, no permanent establishment arose through the project arrangement, the Indian company, or the supervising engineer, as the Indian activities did not create a fixed place or dependent agency presence. Amounts described as interest on deferred instalments were part of the purchase price, not interest on separate indebtedness, and Article VIII did not apply. en-us Fri, 17 Jun 1983 00:00:00 +0530 Mon, 16 Feb 2026 11:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=28470 A double taxation agreement was treated as an additional remedial framework and not a substitute for domestic remedies under the Income-tax Act. The agreement prevailed over section 9(1)(i) to the extent of any inconsistency, so foreign business profits were taxable in India only if attributable to a permanent establishment. On the facts, no permanent establishment arose through the project arrangement, the Indian company, or the supervising engineer, as the Indian activities did not create a fixed place or dependent agency presence. Amounts described as interest on deferred instalments were part of the purchase price, not interest on separate indebtedness, and Article VIII did not apply. Case-Laws Income Tax Fri, 17 Jun 1983 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=28470