https://www.taxtmi.com/caselaws?id=376200 Receipts for managerial and technical services were examined under the India-UAE DTAA and the domestic deeming rule for fees for technical services. Where the treaty contains no specific FTS article, the treaty position pointed to treatment as business profits, which can be taxed in India only if the recipient has a permanent establishment there. The assessee did not produce conclusive evidence negating a permanent establishment, so the taxability of the receipts depended on further factual verification. The matter was therefore remitted for fresh examination of PE existence and, if established, the resulting tax treatment. en-us Thu, 28 Feb 2019 00:00:00 +0530 Tue, 05 Mar 2019 07:33:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=376200 Receipts for managerial and technical services were examined under the India-UAE DTAA and the domestic deeming rule for fees for technical services. Where the treaty contains no specific FTS article, the treaty position pointed to treatment as business profits, which can be taxed in India only if the recipient has a permanent establishment there. The assessee did not produce conclusive evidence negating a permanent establishment, so the taxability of the receipts depended on further factual verification. The matter was therefore remitted for fresh examination of PE existence and, if established, the resulting tax treatment. Case-Laws Income Tax Thu, 28 Feb 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=376200