https://www.taxtmi.com/highlights?id=72518 Income accrued in India - engineering package fee and on-site man-day charges - the service rendered by the assessee is in connection with installation/erection of plant and machinery involved in mining of natural resources - Scope of Article 5(2)(g) of India-Portugal DTAA is not merely limited to mining or extraction of natural resources but also covers installation or structure used for exploration and exploitation of nature resources. - The amount paid would not qualify as FTS. - Demand set aside - AT en-us Thu, 12 Oct 2023 11:29:00 +0530 Thu, 12 Oct 2023 11:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=72518 Income accrued in India - engineering package fee and on-site man-day charges - the service rendered by the assessee is in connection with installation/erection of plant and machinery involved in mining of natural resources - Scope of Article 5(2)(g) of India-Portugal DTAA is not merely limited to mining or extraction of natural resources but also covers installation or structure used for exploration and exploitation of nature resources. - The amount paid would not qualify as FTS. - Demand set aside - AT Highlights Income Tax Thu, 12 Oct 2023 11:29:00 +0530 https://www.taxtmi.com/highlights?id=72518