https://www.taxtmi.com/caselaws?id=326412 A UK-based partnership firm was treated as a person and enterprise of a Contracting State for treaty purposes, even though it was not taxed as such in the UK. Construing Articles 3 and 9 of the India-UK tax treaty liberally and in light of the earlier decision on the same assessee, the Court held that the firm had fiscal domicile in the UK. Its income from operation of ships in international traffic was therefore taxable only in that State, and domestic law could not be used to reopen the assessment in India through Section 148 notices. The reassessment notices were set aside. en-us Tue, 22 Dec 2015 00:00:00 +0530 Thu, 14 Apr 2016 10:02:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=326412 A UK-based partnership firm was treated as a person and enterprise of a Contracting State for treaty purposes, even though it was not taxed as such in the UK. Construing Articles 3 and 9 of the India-UK tax treaty liberally and in light of the earlier decision on the same assessee, the Court held that the firm had fiscal domicile in the UK. Its income from operation of ships in international traffic was therefore taxable only in that State, and domestic law could not be used to reopen the assessment in India through Section 148 notices. The reassessment notices were set aside. Case-Laws Income Tax Tue, 22 Dec 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=326412