https://www.taxtmi.com/caselaws?id=785161 Milestone deliverables under a composite contract for design, manufacture, supply, testing and commissioning were held not to constitute fees for technical services because the project management plan, works programme, quality assurance plan and preliminary design were preparatory submissions intrinsically linked to the main supply obligation, not separate managerial, technical or consultancy services. Interest under section 234B was held not leviable against the non-resident assessee for the relevant year, with the later amendment to section 209(1) treated as prospective. Tax deducted at source credit was remanded for verification, while the challenge to initiation of penalty proceedings under section 271(1)(c) was rejected as premature. en-us Wed, 07 Jan 2026 00:00:00 +0530 Mon, 19 Jan 2026 07:36:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785161 Milestone deliverables under a composite contract for design, manufacture, supply, testing and commissioning were held not to constitute fees for technical services because the project management plan, works programme, quality assurance plan and preliminary design were preparatory submissions intrinsically linked to the main supply obligation, not separate managerial, technical or consultancy services. Interest under section 234B was held not leviable against the non-resident assessee for the relevant year, with the later amendment to section 209(1) treated as prospective. Tax deducted at source credit was remanded for verification, while the challenge to initiation of penalty proceedings under section 271(1)(c) was rejected as premature. Case-Laws Income Tax Wed, 07 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785161