https://www.taxtmi.com/caselaws?id=32794 The ruling concluded that the services under the BE&P Agreement were classified as 'royalty' and taxable in India at a rate of 15 percent under the Double Taxation Avoidance Agreement (DTAA). The effective connection between the Permanent Establishment (PE) in India and the services rendered was not established, leading to the exclusion clause in the DTAA not applying. Receipts from the Project Management Services (PMS) Agreement were treated as business income attributable to the PE in India and taxed accordingly. en-us Mon, 30 Mar 2009 00:00:00 +0530 Mon, 03 May 2010 00:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=32794 The ruling concluded that the services under the BE&P Agreement were classified as 'royalty' and taxable in India at a rate of 15 percent under the Double Taxation Avoidance Agreement (DTAA). The effective connection between the Permanent Establishment (PE) in India and the services rendered was not established, leading to the exclusion clause in the DTAA not applying. Receipts from the Project Management Services (PMS) Agreement were treated as business income attributable to the PE in India and taxed accordingly. Case-Laws Income Tax Mon, 30 Mar 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=32794