https://www.taxtmi.com/caselaws?id=242709 Receipts from borrowed services rendered by a Thai resident enterprise were treated as business profits under the India-Thailand DTAA because they arose from ordinary strategic consultancy business and did not fall within royalties or fees for technical services under Article 12. Article 22 could not apply to income already covered by Article 7. The profits were taxable in India only if attributable to a permanent establishment in India, and no such permanent establishment existed. The income was therefore not taxable in India under Articles 12 or 22 and was excluded from total income on that basis. en-us Wed, 10 Jul 2013 00:00:00 +0530 Sun, 19 Jan 2014 16:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=242709 Receipts from borrowed services rendered by a Thai resident enterprise were treated as business profits under the India-Thailand DTAA because they arose from ordinary strategic consultancy business and did not fall within royalties or fees for technical services under Article 12. Article 22 could not apply to income already covered by Article 7. The profits were taxable in India only if attributable to a permanent establishment in India, and no such permanent establishment existed. The income was therefore not taxable in India under Articles 12 or 22 and was excluded from total income on that basis. Case-Laws Income Tax Wed, 10 Jul 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=242709