https://www.taxtmi.com/caselaws?id=400978 The Tribunal held that the provisions of the India-UK Double Taxation Avoidance Agreement (DTAA) override the Income Tax Act, 1961. The remuneration received by the UK Limited Liability Partnership (LLP) for legal services was not considered 'Fee for Technical Services' (FTS) under the DTAA. The Tribunal also ruled that the LLP's income does not fall under Article 15 of the DTAA as it is not applicable to LLPs. The matter of Permanent Establishment (PE) in India was remanded for further verification. The appeal was partly allowed, with certain issues requiring factual confirmation. en-us Fri, 12 Jun 2020 00:00:00 +0530 Mon, 23 Nov 2020 21:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=400978 The Tribunal held that the provisions of the India-UK Double Taxation Avoidance Agreement (DTAA) override the Income Tax Act, 1961. The remuneration received by the UK Limited Liability Partnership (LLP) for legal services was not considered 'Fee for Technical Services' (FTS) under the DTAA. The Tribunal also ruled that the LLP's income does not fall under Article 15 of the DTAA as it is not applicable to LLPs. The matter of Permanent Establishment (PE) in India was remanded for further verification. The appeal was partly allowed, with certain issues requiring factual confirmation. Case-Laws Income Tax Fri, 12 Jun 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=400978