https://www.taxtmi.com/caselaws?id=57380 The Income-tax Appellate Tribunal (ITAT) upheld the Income-tax Officer's decision that a Canadian non-resident company providing field supervision services for the erection and commissioning of mills was subject to section 44D of the Income-tax Act, 1961. The Tribunal determined that the income constituted technical services, rejecting the company's arguments based on contractual terms and nature of services provided in India. The ITAT clarified that section 44D applied to all technical fees received by foreign companies, irrespective of direct or deemed accrual in India, and upheld the tax treatment accordingly. en-us Tue, 10 Jan 1984 00:00:00 +0530 Sun, 06 Feb 2011 02:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=57380 The Income-tax Appellate Tribunal (ITAT) upheld the Income-tax Officer's decision that a Canadian non-resident company providing field supervision services for the erection and commissioning of mills was subject to section 44D of the Income-tax Act, 1961. The Tribunal determined that the income constituted technical services, rejecting the company's arguments based on contractual terms and nature of services provided in India. The ITAT clarified that section 44D applied to all technical fees received by foreign companies, irrespective of direct or deemed accrual in India, and upheld the tax treatment accordingly. Case-Laws Income Tax Tue, 10 Jan 1984 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=57380