https://www.taxtmi.com/caselaws?id=379030 Under Article 5(2)(k)(i) of the India-UK tax treaty, the 90-day threshold had to be computed on an aggregate basis for personnel rendering services in India, excluding periods of leave where no services were actually performed and disallowing multiple counting of the same day for more than one employee. On the facts, the leave period was excluded and the threshold was not met, so no Permanent Establishment arose in India. As a result, receipts for work rendered outside India and the reimbursement component were not taxable in the assessee's hands, and the related additions were deleted. en-us Tue, 16 Apr 2019 00:00:00 +0530 Thu, 25 Apr 2019 10:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=379030 Under Article 5(2)(k)(i) of the India-UK tax treaty, the 90-day threshold had to be computed on an aggregate basis for personnel rendering services in India, excluding periods of leave where no services were actually performed and disallowing multiple counting of the same day for more than one employee. On the facts, the leave period was excluded and the threshold was not met, so no Permanent Establishment arose in India. As a result, receipts for work rendered outside India and the reimbursement component were not taxable in the assessee's hands, and the related additions were deleted. Case-Laws Income Tax Tue, 16 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=379030