https://www.taxtmi.com/caselaws?id=472448 Under the India-Germany treaty, a permanent establishment must be determined separately for each project; personnel presence below the stipulated six-month period and lack of project-office involvement support taxation of relevant consultancy receipts as fees for technical services rather than as profits attributable to a permanent establishment. Receipts under the existing project remained subject to its stated treaty treatment, while projects lacking complete agreements and annexures required fresh document-based verification. The force-of-attraction rule cannot attribute receipts from independent contracts to an existing permanent establishment without its involvement and an effective connection to those transactions. Interest challenges under sections 234A, 234B and 234C succeeded on the established position for identical facts. en-us Fri, 22 Aug 2025 00:00:00 +0530 Tue, 13 Oct 2026 11:35:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472448 Under the India-Germany treaty, a permanent establishment must be determined separately for each project; personnel presence below the stipulated six-month period and lack of project-office involvement support taxation of relevant consultancy receipts as fees for technical services rather than as profits attributable to a permanent establishment. Receipts under the existing project remained subject to its stated treaty treatment, while projects lacking complete agreements and annexures required fresh document-based verification. The force-of-attraction rule cannot attribute receipts from independent contracts to an existing permanent establishment without its involvement and an effective connection to those transactions. Interest challenges under sections 234A, 234B and 234C succeeded on the established position for identical facts. Case-Laws Income Tax Fri, 22 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472448