https://www.taxtmi.com/caselaws?id=339079 Treaty benefits under the India-UK DTAA depend on satisfaction of the treaty residence test, and a UK LLP may qualify where partnership profits are taxed in the UK even if taxation is at partner level. Fees are taxable as fees for technical services only if the recipient is made able to apply technical knowledge, skill or know-how independently in future; mere advisory use is insufficient. Article 15 applies only to an individual, so it does not cover a LLP. Actual reimbursements without markup are not income, services rendered in India require separate factual examination, and interest under section 234B was treated as not leviable on the stated facts. en-us Tue, 31 Jan 2017 00:00:00 +0530 Tue, 14 Feb 2017 12:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=339079 Treaty benefits under the India-UK DTAA depend on satisfaction of the treaty residence test, and a UK LLP may qualify where partnership profits are taxed in the UK even if taxation is at partner level. Fees are taxable as fees for technical services only if the recipient is made able to apply technical knowledge, skill or know-how independently in future; mere advisory use is insufficient. Article 15 applies only to an individual, so it does not cover a LLP. Actual reimbursements without markup are not income, services rendered in India require separate factual examination, and interest under section 234B was treated as not leviable on the stated facts. Case-Laws Income Tax Tue, 31 Jan 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=339079