https://www.taxtmi.com/caselaws?id=334350 Fees for technical services received by a UAE resident were treated as business profits under the Indo-UAE treaty because the agreement did not contain a separate charging article for such income. The domestic-law definition could not be imported to tax the receipt where the treaty's distributive rules otherwise allocated taxing rights. As the services were rendered in the course of the assessee's regular business and no permanent establishment existed in India, Article 7 barred Indian taxation. The residuary and double-taxation elimination provisions could not be used to restore domestic charging provisions. The addition was therefore unsustainable. en-us Fri, 28 Oct 2016 00:00:00 +0530 Thu, 21 May 2026 17:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=334350 Fees for technical services received by a UAE resident were treated as business profits under the Indo-UAE treaty because the agreement did not contain a separate charging article for such income. The domestic-law definition could not be imported to tax the receipt where the treaty's distributive rules otherwise allocated taxing rights. As the services were rendered in the course of the assessee's regular business and no permanent establishment existed in India, Article 7 barred Indian taxation. The residuary and double-taxation elimination provisions could not be used to restore domestic charging provisions. The addition was therefore unsustainable. Case-Laws Income Tax Fri, 28 Oct 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=334350