DDIT v Toyo Engineering Corpn [2012] 22 taxmann.com 18 (MUM. – ITAT) The assessee was an engineering company incorporated in and tax resident of Japan. During the year it was, inter alia engaged in executing certain Project Management Contracts with MRPL, HPL and CFCL. On the perusal of these services, it can be seen that the assessee received consideration towards project management contracts on an overall basis towards (i) Project Management Services ; (ii) Local engineering supervision ; (iii) Construction management and supervision services and ; (iv) Start-up assistance services.