https://www.taxtmi.com/caselaws?id=438194 Under the India-UK DTAA, a UK LLP was held entitled to treaty benefits because its residency position had already been accepted in earlier and later years and no material change was shown. Legal advisory and related support services were not fees for technical services, as the services did not make technical knowledge, skill, experience, know-how or process available to the recipients. No permanent establishment in India was established, since there was no fixed place PE and the service presence was only 13 days, well below the treaty threshold. Reimbursement of actual travel and hotel expenses was also not taxable because it was a pure cost recovery, not income. en-us Thu, 11 May 2023 00:00:00 +0530 Wed, 24 May 2023 16:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=438194 Under the India-UK DTAA, a UK LLP was held entitled to treaty benefits because its residency position had already been accepted in earlier and later years and no material change was shown. Legal advisory and related support services were not fees for technical services, as the services did not make technical knowledge, skill, experience, know-how or process available to the recipients. No permanent establishment in India was established, since there was no fixed place PE and the service presence was only 13 days, well below the treaty threshold. Reimbursement of actual travel and hotel expenses was also not taxable because it was a pure cost recovery, not income. Case-Laws Income Tax Thu, 11 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=438194