https://www.taxtmi.com/caselaws?id=444235 Technical and engineering receipts for engineering packages, drawings, layouts, specifications, manuals, on-site supervision, and man-day charges were held to fall within the India-Portugal DTAA exclusions for services connected with installations or structures used in the exploration or exploitation of natural resources. The services were integrally linked to erection and installation of smelter plants and related facilities, rather than amounting to a standalone transfer of technology. For independent purchase orders, the materials merely enabled the recipients to study and comment on proposals and did not make technology available for independent use. The receipts were therefore not taxable as fees for technical services and the related additions were deleted. en-us Wed, 06 Sep 2023 00:00:00 +0530 Thu, 12 Oct 2023 09:03:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444235 Technical and engineering receipts for engineering packages, drawings, layouts, specifications, manuals, on-site supervision, and man-day charges were held to fall within the India-Portugal DTAA exclusions for services connected with installations or structures used in the exploration or exploitation of natural resources. The services were integrally linked to erection and installation of smelter plants and related facilities, rather than amounting to a standalone transfer of technology. For independent purchase orders, the materials merely enabled the recipients to study and comment on proposals and did not make technology available for independent use. The receipts were therefore not taxable as fees for technical services and the related additions were deleted. Case-Laws Income Tax Wed, 06 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444235