https://www.taxtmi.com/caselaws?id=310722 A United Kingdom partnership firm may qualify for India-UK treaty benefits if its entire income is taxed in the residence state, even where taxation occurs in the partners' hands. The text also states that Article 5(2)(k) creates a distinct deemed permanent establishment for services furnished through personnel in India, and that actual billing for client work cannot be replaced by notional market rates under Article 7 attribution. Reimbursements of actual expenditure without markup are described as non-income, interest under section 234B as not chargeable on these facts, and the force-of-attraction principle as extending taxation to profits connected with Indian projects. en-us Fri, 16 Jul 2010 00:00:00 +0530 Thu, 09 Nov 2023 14:13:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310722 A United Kingdom partnership firm may qualify for India-UK treaty benefits if its entire income is taxed in the residence state, even where taxation occurs in the partners' hands. The text also states that Article 5(2)(k) creates a distinct deemed permanent establishment for services furnished through personnel in India, and that actual billing for client work cannot be replaced by notional market rates under Article 7 attribution. Reimbursements of actual expenditure without markup are described as non-income, interest under section 234B as not chargeable on these facts, and the force-of-attraction principle as extending taxation to profits connected with Indian projects. Case-Laws Income Tax Fri, 16 Jul 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310722