https://www.taxtmi.com/caselaws?id=32097 Income from a composite supply and services contract may be deemed to accrue or arise in India where a non-resident carries on substantial contractual operations through a business connection in India. The analysis applied section 9(1)(i) to attribute profits only to operations performed in India, while treaty relief was examined to limit chargeability accordingly. A permanent establishment was also found under Article 5 because the country manager acted as a dependent agent and the business was partly conducted from a fixed place in India. The treaty consequently permitted taxation only of profits attributable to the Indian operations and the permanent establishment. en-us Tue, 01 Jun 2004 00:00:00 +0530 Thu, 15 Jan 2009 17:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=32097 Income from a composite supply and services contract may be deemed to accrue or arise in India where a non-resident carries on substantial contractual operations through a business connection in India. The analysis applied section 9(1)(i) to attribute profits only to operations performed in India, while treaty relief was examined to limit chargeability accordingly. A permanent establishment was also found under Article 5 because the country manager acted as a dependent agent and the business was partly conducted from a fixed place in India. The treaty consequently permitted taxation only of profits attributable to the Indian operations and the permanent establishment. Case-Laws Income Tax Tue, 01 Jun 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=32097