https://www.taxtmi.com/caselaws?id=58010 Receipts from preliminary studies, data collection, assimilation and feasibility reporting were treated as industrial or commercial profits under the Denmark treaty, and in the absence of a permanent establishment in India they were not taxable in India under Article III. The treaty expression was held broad enough to include technical service receipts where not specifically excluded. Article XIV did not apply because it was confined to professional or personal services derived by an individual, whereas the assessee was a company. Section 9(1)(vii) also could not override the treaty position, so the addition was deleted. en-us Mon, 08 Jul 1991 00:00:00 +0530 Sun, 06 Feb 2011 02:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=58010 Receipts from preliminary studies, data collection, assimilation and feasibility reporting were treated as industrial or commercial profits under the Denmark treaty, and in the absence of a permanent establishment in India they were not taxable in India under Article III. The treaty expression was held broad enough to include technical service receipts where not specifically excluded. Article XIV did not apply because it was confined to professional or personal services derived by an individual, whereas the assessee was a company. Section 9(1)(vii) also could not override the treaty position, so the addition was deleted. Case-Laws Income Tax Mon, 08 Jul 1991 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=58010