https://www.taxtmi.com/caselaws?id=204123 A fiscally transparent UK partnership may qualify for India-UK treaty benefits if the full partnership income is taxed in the residence State through taxation of the partners. Article 5(2)(k) was treated as an independent deemed permanent establishment provision covering services furnished through personnel for the required duration, including professional services. Under Article 7(2), arm's length attribution applies to intra-enterprise dealings and not to substituting actual client receipts with notional market rates. Reimbursements supported by evidence and incurred without markup were not income. Interest under section 234B was not chargeable where tax was deductible at source, and the force of attraction principle extended Indian taxability to income connected with Indian projects. en-us Fri, 16 Jul 2010 00:00:00 +0530 Thu, 28 Aug 2025 14:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=204123 A fiscally transparent UK partnership may qualify for India-UK treaty benefits if the full partnership income is taxed in the residence State through taxation of the partners. Article 5(2)(k) was treated as an independent deemed permanent establishment provision covering services furnished through personnel for the required duration, including professional services. Under Article 7(2), arm's length attribution applies to intra-enterprise dealings and not to substituting actual client receipts with notional market rates. Reimbursements supported by evidence and incurred without markup were not income. Interest under section 234B was not chargeable where tax was deductible at source, and the force of attraction principle extended Indian taxability to income connected with Indian projects. Case-Laws Income Tax Fri, 16 Jul 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=204123