https://www.taxtmi.com/highlights?id=95580 Receipts for supply of drawings and designs were held not taxable in India because a coordinate bench in the taxpayer's own case had accepted non-taxability; additions were directed to be deleted. Consideration for supervision of erection and commissioning for a period of less than six months was held to constitute fees for technical services under domestic law and Article 12(4) of the India-Germany DTAA; it was therefore taxable in India irrespective of PE. For AY 2020-21, where supervisory activity exceeded six months, a PE was established and income had to be computed under Article 7 on a net basis; as the AO gave no reasons to reject audited books showing a loss, no income was taxable from that activity. Interest under section 234B was consequential and section 234C was chargeable only on returned income. - ITAT en-us Wed, 31 Dec 2025 09:17:38 +0530 Wed, 31 Dec 2025 09:17:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=95580 Receipts for supply of drawings and designs were held not taxable in India because a coordinate bench in the taxpayer's own case had accepted non-taxability; additions were directed to be deleted. Consideration for supervision of erection and commissioning for a period of less than six months was held to constitute fees for technical services under domestic law and Article 12(4) of the India-Germany DTAA; it was therefore taxable in India irrespective of PE. For AY 2020-21, where supervisory activity exceeded six months, a PE was established and income had to be computed under Article 7 on a net basis; as the AO gave no reasons to reject audited books showing a loss, no income was taxable from that activity. Interest under section 234B was consequential and section 234C was chargeable only on returned income. - ITAT Highlights Income Tax Wed, 31 Dec 2025 09:17:38 +0530 https://www.taxtmi.com/highlights?id=95580