https://www.taxtmi.com/caselaws?id=216070 A Swiss partnership was held unable to claim residence or treaty benefits under the India-Switzerland tax treaty because it was not itself a taxable person under Swiss law, even though its partners were taxed on their shares. The ruling further treated legal fees earned for services connected with an Indian dispute as income arising in India, since the work related to an Indian project and included activity in India; the foreign adjudication venue did not break the Indian source nexus. As a result, the fees were taxable in India, and the withholding tax issue followed from that finding. en-us Mon, 27 Aug 2012 00:00:00 +0530 Wed, 29 Aug 2012 14:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=216070 A Swiss partnership was held unable to claim residence or treaty benefits under the India-Switzerland tax treaty because it was not itself a taxable person under Swiss law, even though its partners were taxed on their shares. The ruling further treated legal fees earned for services connected with an Indian dispute as income arising in India, since the work related to an Indian project and included activity in India; the foreign adjudication venue did not break the Indian source nexus. As a result, the fees were taxable in India, and the withholding tax issue followed from that finding. Case-Laws Income Tax Mon, 27 Aug 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=216070