https://www.taxtmi.com/caselaws?id=751074 Treaty relief under the India-UK DTAA was allowed where UK tax residency certificates established residence for treaty purposes. Offshore supply receipts were held not taxable in India because the contracts separated offshore and onshore work, the Indian entity acted as an independent contractor for onshore scope, and no business connection, dependent agent PE, fixed place PE or construction PE was proved; section 44BBB also did not apply. Global operation fee receipts were taxable only to the extent already offered, as the remaining managerial or support services did not satisfy the make available test under Article 13(4)(c). Interest under sections 234B, 234C and 234D was largely deleted, with section 234A left for verification for one year. en-us Wed, 13 Mar 2024 00:00:00 +0530 Fri, 14 Nov 2025 10:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=751074 Treaty relief under the India-UK DTAA was allowed where UK tax residency certificates established residence for treaty purposes. Offshore supply receipts were held not taxable in India because the contracts separated offshore and onshore work, the Indian entity acted as an independent contractor for onshore scope, and no business connection, dependent agent PE, fixed place PE or construction PE was proved; section 44BBB also did not apply. Global operation fee receipts were taxable only to the extent already offered, as the remaining managerial or support services did not satisfy the make available test under Article 13(4)(c). Interest under sections 234B, 234C and 234D was largely deleted, with section 234A left for verification for one year. Case-Laws Income Tax Wed, 13 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=751074