https://www.taxtmi.com/caselaws?id=14963 Where business profits were attributable to a permanent establishment in Sri Lanka, the India-Sri Lanka tax treaty was applied to allocate taxation to Sri Lanka, so the receipts were not taxable in India on the facts found. The court also noted that the income's not having been actually taxed in Sri Lanka did not by itself create Indian tax liability or raise a double taxation relief issue. As the Tribunal's treaty-based view on the situs of taxation was left undisturbed, no referable question of law arose and the Department's request for reference failed. en-us Mon, 28 Jul 1997 00:00:00 +0530 Mon, 27 Jul 2009 13:12:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=14963 Where business profits were attributable to a permanent establishment in Sri Lanka, the India-Sri Lanka tax treaty was applied to allocate taxation to Sri Lanka, so the receipts were not taxable in India on the facts found. The court also noted that the income's not having been actually taxed in Sri Lanka did not by itself create Indian tax liability or raise a double taxation relief issue. As the Tribunal's treaty-based view on the situs of taxation was left undisturbed, no referable question of law arose and the Department's request for reference failed. Case-Laws Income Tax Mon, 28 Jul 1997 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=14963