India-Austria DTAA: Subcontractor's Mining Services Not a Permanent Establishment, Taxed as Technical Fees Per AAR Ruling.

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....DTAA between India and Austria - subcontract - PE - That person can at best be said to render technical services or services 'in connection with' the mining activity undertaken by the original contractor - the revenues earned by the applicant are not taxable in accordance with section 44BB and are taxable only as fees for technical services. - AAR....