https://www.taxtmi.com/caselaws?id=307607 A non-resident's receipts from independent engineering contracts were held taxable only in accordance with the applicable treaty provision for fees for technical services where no permanent establishment in India was shown. The force of attraction rule was found inapplicable because the contracts were treated as independent and the Revenue could not establish a sufficient project nexus or common link with an Indian PE. On one contract, the receipts were deleted from assessment for want of PE; on another, the income was taxed at the treaty rate rather than under section 44DA. Interest under sections 234B and 234C was also held not leviable where tax was deductible at source. en-us Wed, 16 Nov 2022 00:00:00 +0530 Mon, 24 Apr 2023 21:07:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307607 A non-resident's receipts from independent engineering contracts were held taxable only in accordance with the applicable treaty provision for fees for technical services where no permanent establishment in India was shown. The force of attraction rule was found inapplicable because the contracts were treated as independent and the Revenue could not establish a sufficient project nexus or common link with an Indian PE. On one contract, the receipts were deleted from assessment for want of PE; on another, the income was taxed at the treaty rate rather than under section 44DA. Interest under sections 234B and 234C was also held not leviable where tax was deductible at source. Case-Laws Income Tax Wed, 16 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307607