Income from supervisory services rendered in connection with commissioning of a power project is business income in terms of article 7 of Indo-German DTAA rws 44D & 115A

IN THE ITAT DELHI BENCH ‘H’ Voith Siemens Hydro Kraftwerkstechnik Gmbh & Co. KG Versus Deputy Director of Income-tax, Circle 2(2), International Taxation IT APPEAL NO. 5652 (DELHI) OF 2010 [ASSESSMENT YEAR 2007-08] OCTOBER 19, 2012 ORDER Chandra Mohan Garg, Judicial Member This appeal has been preferred by the assessee against the order of Assessing Officer, Dispute Resolution Panel-II, New Delhi, on the following grounds of appeal:- “1.  That the order of the ld. AO as per the directions of DRP is bad both in law and on facts of the case.  2.  That t...