https://www.taxtmi.com/caselaws?id=339530 The assessee's return and notes were required to be read as a whole, and the voluntary offer of income did not amount to acceptance of a service permanent establishment for the relevant period under Article 5(2)(k) of the India-UK Tax Treaty. The Tribunal noted that the assessee specifically claimed the 90-day threshold for November 2008 to March 2009 was not exceeded, and that the lower authorities had not dealt with the treaty conditions in a reasoned manner. The finding of a permanent establishment for that period was set aside, and the matter was remanded to the Assessing Officer for fresh adjudication by a speaking order after considering the assessee's contentions. en-us Wed, 08 Feb 2017 00:00:00 +0530 Wed, 01 Mar 2017 09:05:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=339530 The assessee's return and notes were required to be read as a whole, and the voluntary offer of income did not amount to acceptance of a service permanent establishment for the relevant period under Article 5(2)(k) of the India-UK Tax Treaty. The Tribunal noted that the assessee specifically claimed the 90-day threshold for November 2008 to March 2009 was not exceeded, and that the lower authorities had not dealt with the treaty conditions in a reasoned manner. The finding of a permanent establishment for that period was set aside, and the matter was remanded to the Assessing Officer for fresh adjudication by a speaking order after considering the assessee's contentions. Case-Laws Income Tax Wed, 08 Feb 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=339530