https://www.taxtmi.com/caselaws?id=19665 Foreign partnership income from a Malaysian firm was treated as excluded from the assessee's Indian assessment under the applicable double taxation avoidance agreement. The treaty's permanent-establishment requirement was not met because the Tribunal found no permanent establishment of the Malaysian firm in India; its finding was sustained. Malaysian income was also not includible in total income for rate purposes, based on the relevant treaty provisions, and no Malaysian tax certificate was required. The substantive treaty questions were resolved in favour of the assessee and against the Revenue. en-us Tue, 15 Mar 1994 00:00:00 +0530 Sat, 07 Nov 2009 17:00:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=19665 Foreign partnership income from a Malaysian firm was treated as excluded from the assessee's Indian assessment under the applicable double taxation avoidance agreement. The treaty's permanent-establishment requirement was not met because the Tribunal found no permanent establishment of the Malaysian firm in India; its finding was sustained. Malaysian income was also not includible in total income for rate purposes, based on the relevant treaty provisions, and no Malaysian tax certificate was required. The substantive treaty questions were resolved in favour of the assessee and against the Revenue. Case-Laws Income Tax Tue, 15 Mar 1994 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=19665