https://www.taxtmi.com/caselaws?id=59734 For a construction or project PE, durations of separate contracts cannot be aggregated unless the Revenue shows artificial splitting or that the activities are commercially or geographically interdependent and form one coherent whole; absent such proof, each project is tested separately, and no PE was found. Barge-hire receipts were treated as royalty and also fell within the domestic computation regime under section 44BB, so that part of the assessment was sustained. Interest under sections 234B and 234C was held not leviable on the facts. en-us Mon, 05 Apr 2010 00:00:00 +0530 Wed, 04 Oct 2023 14:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59734 For a construction or project PE, durations of separate contracts cannot be aggregated unless the Revenue shows artificial splitting or that the activities are commercially or geographically interdependent and form one coherent whole; absent such proof, each project is tested separately, and no PE was found. Barge-hire receipts were treated as royalty and also fell within the domestic computation regime under section 44BB, so that part of the assessment was sustained. Interest under sections 234B and 234C was held not leviable on the facts. Case-Laws Income Tax Mon, 05 Apr 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59734