https://www.taxtmi.com/caselaws?id=35358 A composite architectural consultancy contract requiring preparation of drawings, designs, specifications and project reports, together with continuing technical and supervisory obligations, was treated as a consultancy arrangement rather than an outright sale of drawings. The receipts were therefore characterised as fees for technical services under the Income-tax Act and the DTAA, even though drawings were electronically delivered and part of the work was subcontracted. On the facts, the enterprise's activities in India were limited and temporary, so no permanent establishment was found in India. Questions dependent on the existence of a permanent establishment accordingly did not survive. en-us Fri, 29 Jan 2010 00:00:00 +0530 Thu, 31 Jan 2013 18:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=35358 A composite architectural consultancy contract requiring preparation of drawings, designs, specifications and project reports, together with continuing technical and supervisory obligations, was treated as a consultancy arrangement rather than an outright sale of drawings. The receipts were therefore characterised as fees for technical services under the Income-tax Act and the DTAA, even though drawings were electronically delivered and part of the work was subcontracted. On the facts, the enterprise's activities in India were limited and temporary, so no permanent establishment was found in India. Questions dependent on the existence of a permanent establishment accordingly did not survive. Case-Laws Income Tax Fri, 29 Jan 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=35358