https://www.taxtmi.com/caselaws?id=751207 A UK limited liability partnership carrying on legal services was treated as eligible for India-UK treaty relief where the relevant income was taxed in the UK in the hands of its partners. The Tribunal held that treaty residence depends on whether the income is liable to tax in the residence State, not on whether tax is collected from the entity or through pass-through taxation. On that basis, denial of treaty benefit on transparency grounds was rejected, and the alternative contention that the receipts were fees for technical services did not survive once treaty protection applied. en-us Mon, 08 Apr 2024 00:00:00 +0530 Wed, 10 Apr 2024 08:43:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=751207 A UK limited liability partnership carrying on legal services was treated as eligible for India-UK treaty relief where the relevant income was taxed in the UK in the hands of its partners. The Tribunal held that treaty residence depends on whether the income is liable to tax in the residence State, not on whether tax is collected from the entity or through pass-through taxation. On that basis, denial of treaty benefit on transparency grounds was rejected, and the alternative contention that the receipts were fees for technical services did not survive once treaty protection applied. Case-Laws Income Tax Mon, 08 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=751207