https://www.taxtmi.com/caselaws?id=296091 The court ruled that income from investments in Indian securities by companies incorporated in the Netherlands should be assessed in the hands of the funds PQR and STU, not the applicants or JKL. The India-Netherlands Double Taxation Avoidance Agreement benefits were not applicable to the funds or JKL. The contributions were not classified as revocable transfers, and PQR and STU were not considered trusts under Section 161. Ultimately, the income earned on behalf of PQR and STU was deemed taxable in India, and JKL could not claim treaty benefits on their behalf. en-us Tue, 21 Jan 2020 00:00:00 +0530 Sat, 03 Jul 2021 08:55:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=296091 The court ruled that income from investments in Indian securities by companies incorporated in the Netherlands should be assessed in the hands of the funds PQR and STU, not the applicants or JKL. The India-Netherlands Double Taxation Avoidance Agreement benefits were not applicable to the funds or JKL. The contributions were not classified as revocable transfers, and PQR and STU were not considered trusts under Section 161. Ultimately, the income earned on behalf of PQR and STU was deemed taxable in India, and JKL could not claim treaty benefits on their behalf. Case-Laws Income Tax Tue, 21 Jan 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=296091