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

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 .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X