https://www.taxtmi.com/caselaws?id=59337 Under the India-Austria Double Taxation Avoidance Agreement, fees for technical services were taxable in India only to the extent attributable to services actually performed in India, and business profits of a foreign enterprise were taxable only if attributable to a permanent establishment in India. The record showed the work was to be performed in Austria, with no services rendered in India and no permanent establishment established in India. On those facts, the receipt was not taxable in India and the addition was unsustainable. en-us Thu, 30 Sep 2004 00:00:00 +0530 Tue, 28 Dec 2010 19:01:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59337 Under the India-Austria Double Taxation Avoidance Agreement, fees for technical services were taxable in India only to the extent attributable to services actually performed in India, and business profits of a foreign enterprise were taxable only if attributable to a permanent establishment in India. The record showed the work was to be performed in Austria, with no services rendered in India and no permanent establishment established in India. On those facts, the receipt was not taxable in India and the addition was unsustainable. Case-Laws Income Tax Thu, 30 Sep 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59337