India-Spain DTAA: No Permanent Establishment for DPIR and Engineering Services; Taxed as Fees for Technical Services per Article 13(4.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....PE in India - India-Spain DTAA - business profit carried out through PE - Services rendered from outside India - there is no Permanent Establishments during the relevant assessment year 2007-08 for the activities relating to DPIR and engineering services from which the assessee has earned the revenue and same cannot be taxed as business profit carried out through PE in India. It is in the nature of FTS which is to be taxed in accordance with Article 13(4) of India-Spain DTAA....