https://www.taxtmi.com/caselaws?id=800950 Project-specific permanent establishment principles limit the force of attraction rule: a PE established for the Baglihar project cannot be connected to receipts from separate consultancy contracts unless its involvement or nexus is established. Where no personnel visit India or personnel presence remains below 183 days, treaty conditions for taxing consultancy income as business profits through a PE under Articles 5(2) and 15(2) are not met. Such consultancy receipts fall under Article 12 as fees for technical services, taxable at the applicable treaty rate rather than as PE-attributable business profits. en-us Mon, 07 Sep 2026 00:00:00 +0530 Wed, 14 Oct 2026 06:17:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800950 Project-specific permanent establishment principles limit the force of attraction rule: a PE established for the Baglihar project cannot be connected to receipts from separate consultancy contracts unless its involvement or nexus is established. Where no personnel visit India or personnel presence remains below 183 days, treaty conditions for taxing consultancy income as business profits through a PE under Articles 5(2) and 15(2) are not met. Such consultancy receipts fall under Article 12 as fees for technical services, taxable at the applicable treaty rate rather than as PE-attributable business profits. Case-Laws Income Tax Mon, 07 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800950