https://www.taxtmi.com/caselaws?id=63839 Interest on an income-tax refund received by a UK resident with a permanent establishment in India was treated as business profits because the debt-claim was effectively connected with that permanent establishment. Article 12(6) of the India-UK DTAA excluded the concessional 15% rate under Article 12(2) in such circumstances and directed taxation under Article 7. The advance ruling cited by the assessee was distinguishable because it involved no permanent establishment in India. The treaty benefit under Article 12(2) was therefore unavailable, and the interest was taxed as business profits. en-us Tue, 30 Sep 2008 00:00:00 +0530 Mon, 06 Aug 2012 17:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=63839 Interest on an income-tax refund received by a UK resident with a permanent establishment in India was treated as business profits because the debt-claim was effectively connected with that permanent establishment. Article 12(6) of the India-UK DTAA excluded the concessional 15% rate under Article 12(2) in such circumstances and directed taxation under Article 7. The advance ruling cited by the assessee was distinguishable because it involved no permanent establishment in India. The treaty benefit under Article 12(2) was therefore unavailable, and the interest was taxed as business profits. Case-Laws Income Tax Tue, 30 Sep 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=63839