https://www.taxtmi.com/caselaws?id=312298 Interest on income-tax refund was treated as falling under the India-Australia DTAA interest article rather than as business income attributable to the permanent establishment, because it was not effectively connected with PE assets or activity. For the Hazira project, the analysis applied a project-wise approach and noted that the relevant engineering and other services were performed outside India through overseas subcontracting, so the overseas receipts were not taxable in India merely because the overall contract related to an Indian project. Interest under section 234B was also not sustained where the income was subject to tax deduction at source and no advance-tax liability was shown to arise. en-us Thu, 13 Apr 2017 00:00:00 +0530 Thu, 29 Feb 2024 18:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=312298 Interest on income-tax refund was treated as falling under the India-Australia DTAA interest article rather than as business income attributable to the permanent establishment, because it was not effectively connected with PE assets or activity. For the Hazira project, the analysis applied a project-wise approach and noted that the relevant engineering and other services were performed outside India through overseas subcontracting, so the overseas receipts were not taxable in India merely because the overall contract related to an Indian project. Interest under section 234B was also not sustained where the income was subject to tax deduction at source and no advance-tax liability was shown to arise. Case-Laws Income Tax Thu, 13 Apr 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=312298