https://www.taxtmi.com/caselaws?id=368005 India-UK DTAA treaty relief, the characterisation of legal consultancy receipts, and the interaction between section 90(2) and section 9(1)(vii) are examined, alongside permanent establishment under Article 5(2)(k)(i), the meaning of "any 12 month period," and taxation of services performed outside India. The note also addresses Article 15, treatment of expense reimbursements without mark-up, and leviability of interest under sections 234B and 234C. It records that treaty provisions, when more beneficial, govern the taxability analysis and that factual verification may still be required on PE presence and day count. 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 treaty relief, the characterisation of legal consultancy receipts, and the interaction between section 90(2) and section 9(1)(vii) are examined, alongside permanent establishment under Article 5(2)(k)(i), the meaning of "any 12 month period," and taxation of services performed outside India. The note also addresses Article 15, treatment of expense reimbursements without mark-up, and leviability of interest under sections 234B and 234C. It records that treaty provisions, when more beneficial, govern the taxability analysis and that factual verification may still be required on PE presence and day count. Case-Laws Income Tax Wed, 29 Aug 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=368005