https://www.taxtmi.com/caselaws?id=31936 For a non-resident providing composite legal advisory services, only the portion of fees attributable to services actually performed in India was taxable under Article 15 of the DTAA read with sections 5 and 9 of the Income-tax Act, 1961. Services rendered outside India could not be taxed merely because the underlying project or client use was connected with India. The Court also accepted billing by hours and time sheets as a reliable method to allocate income between Indian and ? need English. Let's craft cleanly. The time-based computation could be used to identify the India-linked portion, and the Revenue could not treat the composite fee as an inseverable whole. Income assessable in India was therefore confined to the services performed within India. en-us Fri, 19 Dec 2008 00:00:00 +0530 Fri, 29 Jan 2010 12:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=31936 For a non-resident providing composite legal advisory services, only the portion of fees attributable to services actually performed in India was taxable under Article 15 of the DTAA read with sections 5 and 9 of the Income-tax Act, 1961. Services rendered outside India could not be taxed merely because the underlying project or client use was connected with India. The Court also accepted billing by hours and time sheets as a reliable method to allocate income between Indian and ? need English. Let's craft cleanly. The time-based computation could be used to identify the India-linked portion, and the Revenue could not treat the composite fee as an inseverable whole. Income assessable in India was therefore confined to the services performed within India. Case-Laws Income Tax Fri, 19 Dec 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=31936