https://www.taxtmi.com/caselaws?id=270244 A partnership firm registered in the UK was considered entitled to the India-UK Double Taxation Avoidance Agreement because treaty coverage was extended to persons resident in one or both contracting states, and a firm could fall within that framework where domestic law treats it as a person liable to tax. The analysis relied on the Income-tax Act definition of "person" and the fact that a firm is treated as an assessee for charge purposes, so treaty protection could not be denied merely because the firm was not taxed as a separate entity under UK domestic law. On that basis, the receipts were treated as not taxable in India. en-us Fri, 09 Oct 2015 00:00:00 +0530 Fri, 01 Jan 2016 13:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=270244 A partnership firm registered in the UK was considered entitled to the India-UK Double Taxation Avoidance Agreement because treaty coverage was extended to persons resident in one or both contracting states, and a firm could fall within that framework where domestic law treats it as a person liable to tax. The analysis relied on the Income-tax Act definition of "person" and the fact that a firm is treated as an assessee for charge purposes, so treaty protection could not be denied merely because the firm was not taxed as a separate entity under UK domestic law. On that basis, the receipts were treated as not taxable in India. Case-Laws Income Tax Fri, 09 Oct 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=270244