https://www.taxtmi.com/caselaws?id=180692 The dominant issue was whether professional fees earned by a foreign partnership from legal services rendered in India were taxable in India under s.90 read with the India-UK DTAA. The Tribunal held that even if the receipts were "fees for technical services," Article 13(5)(e) routed taxation to Article 15 (independent personal services), and the term "member" in Article 15 is of widest import, covering employee-lawyers representing the firm; since such presence in India exceeded 90 days, the income was taxable in India, rendering other treaty arguments largely academic. On deductibility, salary costs of staff were held allowable, subject to AO verification, and the appeal was partly allowed. en-us Thu, 27 Sep 2001 00:00:00 +0530 Tue, 23 Dec 2025 11:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=180692 The dominant issue was whether professional fees earned by a foreign partnership from legal services rendered in India were taxable in India under s.90 read with the India-UK DTAA. The Tribunal held that even if the receipts were "fees for technical services," Article 13(5)(e) routed taxation to Article 15 (independent personal services), and the term "member" in Article 15 is of widest import, covering employee-lawyers representing the firm; since such presence in India exceeded 90 days, the income was taxable in India, rendering other treaty arguments largely academic. On deductibility, salary costs of staff were held allowable, subject to AO verification, and the appeal was partly allowed. Case-Laws Income Tax Thu, 27 Sep 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=180692