https://www.taxtmi.com/caselaws?id=253247 A partnership earning shipping income in international traffic was held entitled to protection under the India-UK treaty because a firm is a person under the Income-tax Act and falls within the treaty definition when taxed as a unit. The court also found that the reopening notice was supported by reasons to believe of escaped assessment, since the later-discovered position showed the partnership, not the company earlier reflected in the return records, as the relevant taxable entity. On the facts, the Revenue could not deny treaty coverage while proceeding against the partnership as the assessable unit, and the reassessment notices were set aside. en-us Fri, 07 Nov 2014 00:00:00 +0530 Wed, 18 Feb 2015 16:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=253247 A partnership earning shipping income in international traffic was held entitled to protection under the India-UK treaty because a firm is a person under the Income-tax Act and falls within the treaty definition when taxed as a unit. The court also found that the reopening notice was supported by reasons to believe of escaped assessment, since the later-discovered position showed the partnership, not the company earlier reflected in the return records, as the relevant taxable entity. On the facts, the Revenue could not deny treaty coverage while proceeding against the partnership as the assessable unit, and the reassessment notices were set aside. Case-Laws Income Tax Fri, 07 Nov 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=253247