https://www.taxtmi.com/caselaws?id=60747 The taxability of technical know-how fees received for deputed engineers depended on the true character of the design and construction supervision arrangement, especially whether the personnel remained the assessee's employees or became employees of the Indian company. The Tribunal noted that the governing principles on accrual, deemed accrual, and business connection could not be applied correctly without resolving that factual question, because services rendered in India and technical information furnished from outside India may have different tax consequences. The matter was therefore sent back for fresh examination of the employment status and related facts before a decision on Indian taxability. en-us Sat, 07 Jan 1984 00:00:00 +0530 Sun, 06 Feb 2011 03:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=60747 The taxability of technical know-how fees received for deputed engineers depended on the true character of the design and construction supervision arrangement, especially whether the personnel remained the assessee's employees or became employees of the Indian company. The Tribunal noted that the governing principles on accrual, deemed accrual, and business connection could not be applied correctly without resolving that factual question, because services rendered in India and technical information furnished from outside India may have different tax consequences. The matter was therefore sent back for fresh examination of the employment status and related facts before a decision on Indian taxability. Case-Laws Income Tax Sat, 07 Jan 1984 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=60747