https://www.taxtmi.com/caselaws?id=19665 Foreign partnership income was held excluded from the assessee's Indian assessment under the applicable treaty arrangement, following the earlier connected decision, and the Revenue failed on that issue. The Tribunal's factual finding that the Malaysian firm had no permanent establishment in India satisfied the treaty test under article 7, so the income could not be taxed in India on that basis either. The article also states that the Malaysian income was not includible in total income for rate purposes, and that a certificate of taxation in Malaysia was unnecessary. The Tribunal's treaty-based exclusion of the Malaysian income was thus sustained on all substantive questions. 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 was held excluded from the assessee's Indian assessment under the applicable treaty arrangement, following the earlier connected decision, and the Revenue failed on that issue. The Tribunal's factual finding that the Malaysian firm had no permanent establishment in India satisfied the treaty test under article 7, so the income could not be taxed in India on that basis either. The article also states that the Malaysian income was not includible in total income for rate purposes, and that a certificate of taxation in Malaysia was unnecessary. The Tribunal's treaty-based exclusion of the Malaysian income was thus sustained on all substantive questions. Case-Laws Income Tax Tue, 15 Mar 1994 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=19665