https://www.taxtmi.com/caselaws?id=445543 Article 5(2)(k) of the India-UK DTAA was treated as a deeming service-PE provision, and the distinction between furnishing and rendering services was rejected; on the stated facts, the duration test was met and a permanent establishment in India was found. Once PE attribution applied, only profits attributable to services rendered in India were taxable, and reimbursements or disbursements representing actual expenses without markup were not income. Interest under section 234B was held not leviable on a non-resident where tax was deductible at source. Article 15 was held applicable only to individuals and not to the assessee-firm, but that did not alter taxability under Article 7. en-us Wed, 11 Oct 2023 00:00:00 +0530 Thu, 09 Nov 2023 14:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445543 Article 5(2)(k) of the India-UK DTAA was treated as a deeming service-PE provision, and the distinction between furnishing and rendering services was rejected; on the stated facts, the duration test was met and a permanent establishment in India was found. Once PE attribution applied, only profits attributable to services rendered in India were taxable, and reimbursements or disbursements representing actual expenses without markup were not income. Interest under section 234B was held not leviable on a non-resident where tax was deductible at source. Article 15 was held applicable only to individuals and not to the assessee-firm, but that did not alter taxability under Article 7. Case-Laws Income Tax Wed, 11 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445543