https://www.taxtmi.com/caselaws?id=368005 India-UK DTAA treatment governs legal consultancy receipts where treaty eligibility is available and the treaty is more beneficial than domestic law: such receipts do not constitute fees for technical services under Article 13. Permanent establishment status for service activities depends on the days spent in India during the relevant previous or financial year and requires factual verification. Services rendered outside India are not taxable merely because related services are performed in India. Article 15 applies to an individual's independent personal services, not a partnership entity. Actual expense reimbursements without mark-up are excluded where no income element is established, and interest for default in advance-tax payment is not chargeable on the stated facts. en-us Wed, 29 Aug 2018 00:00:00 +0530 Sat, 29 Sep 2018 06:47:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=368005 India-UK DTAA treatment governs legal consultancy receipts where treaty eligibility is available and the treaty is more beneficial than domestic law: such receipts do not constitute fees for technical services under Article 13. Permanent establishment status for service activities depends on the days spent in India during the relevant previous or financial year and requires factual verification. Services rendered outside India are not taxable merely because related services are performed in India. Article 15 applies to an individual's independent personal services, not a partnership entity. Actual expense reimbursements without mark-up are excluded where no income element is established, and interest for default in advance-tax payment is not chargeable on the stated facts. Case-Laws Income Tax Wed, 29 Aug 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=368005