Taxability of receipts under the India-UK treaty followed earlier bench rulings and was upheld against the assessee.

Receipts not attributable to the assessee's permanent establishment were examined for taxability in India as fees for technical services under Article 13 of the India-United Kingdom tax treaty. The Tribunal treated the issue as already covered by earlier coordinate bench decisions in the assessee's own case for prior assessment years, and the parties accepted that the same factual and legal controversy arose again. Following the earlier view, the Tribunal declined to take a different view on the disputed receipts and held them taxable in India, deciding the issue against the assessee and in favour of the Revenue.

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Issues: Whether the receipt not attributable to the assessee's permanent establishment could be taxed in India as fees for technical services under Article 13 of the India-United Kingdom tax treaty.

Analysis: The issue was treated as covered against the assessee by earlier coordinate bench decisions in the assessee's own case for preceding assessment years. The parties accepted that the same factual and legal controversy arose in the present year and required the same treatment. Following the earlier view, the Tribunal declined to take a different view on the taxability of the disputed receipts.

Conclusion: The issue was decided against the assessee and in favour of the Revenue.

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