https://www.taxtmi.com/caselaws?id=423599 Service receipts from general, administrative, business planning, coordination and engineering work performed for an Indian subsidiary were treated as business income under the India-Thailand treaty. In the absence of a specific fees for technical services article, such receipts do not move to the residual income article merely because the recipient has no permanent establishment in India. The residual article applies only to income not otherwise dealt with by another treaty article. On that basis, the receipts fell within the business profits article and were not taxable in India without a permanent establishment. en-us Fri, 27 May 2022 00:00:00 +0530 Mon, 01 Jun 2026 17:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=423599 Service receipts from general, administrative, business planning, coordination and engineering work performed for an Indian subsidiary were treated as business income under the India-Thailand treaty. In the absence of a specific fees for technical services article, such receipts do not move to the residual income article merely because the recipient has no permanent establishment in India. The residual article applies only to income not otherwise dealt with by another treaty article. On that basis, the receipts fell within the business profits article and were not taxable in India without a permanent establishment. Case-Laws Income Tax Fri, 27 May 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=423599