https://www.taxtmi.com/caselaws?id=435526 A partnership firm incorporated in the UK was treated as entitled to India-UK DTAA benefits where its profits were taxed in the UK in the hands of the firm or partners. Legal drafting and due diligence services were held not to constitute fees for technical services under the India-UK treaty or domestic law, and the treaty "make available" condition was not shown. On the facts, no permanent establishment in India was established because personnel were present for only 17 days, below the 90-day threshold relied on. Article 15, being confined to individuals, was held inapplicable to a firm under both the India-UK and India-Singapore DTAAs. Actual expense reimbursements without markup were not income. en-us Wed, 22 Feb 2023 00:00:00 +0530 Tue, 21 Mar 2023 12:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=435526 A partnership firm incorporated in the UK was treated as entitled to India-UK DTAA benefits where its profits were taxed in the UK in the hands of the firm or partners. Legal drafting and due diligence services were held not to constitute fees for technical services under the India-UK treaty or domestic law, and the treaty "make available" condition was not shown. On the facts, no permanent establishment in India was established because personnel were present for only 17 days, below the 90-day threshold relied on. Article 15, being confined to individuals, was held inapplicable to a firm under both the India-UK and India-Singapore DTAAs. Actual expense reimbursements without markup were not income. Case-Laws Income Tax Wed, 22 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=435526