https://www.taxtmi.com/caselaws?id=436960 Consultancy receipts under the JKHCL and JVL contracts were held taxable as fee for technical services under Article 12 of the India-Germany DTAA, because the record did not establish a fixed place permanent establishment, no specific permanent establishment was alleged for the JVL contract, and the force of attraction rule was not shown to apply; the additions under sections 44D and 44DA were deleted. Interest under sections 234B and 234C was held not leviable where tax was deductible at source. TDS credit was directed to be verified and granted in accordance with law, resulting in partial relief to the assessees. en-us Fri, 31 Mar 2023 00:00:00 +0530 Mon, 24 Apr 2023 11:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=436960 Consultancy receipts under the JKHCL and JVL contracts were held taxable as fee for technical services under Article 12 of the India-Germany DTAA, because the record did not establish a fixed place permanent establishment, no specific permanent establishment was alleged for the JVL contract, and the force of attraction rule was not shown to apply; the additions under sections 44D and 44DA were deleted. Interest under sections 234B and 234C was held not leviable where tax was deductible at source. TDS credit was directed to be verified and granted in accordance with law, resulting in partial relief to the assessees. Case-Laws Income Tax Fri, 31 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=436960