https://www.taxtmi.com/caselaws?id=753539 Where the India-Thailand DTAA contains no separate article for fees for technical services, such receipts are not moved to the residuary article if they arise in the ordinary course of the enterprise's business. The proper treaty character is business profits under Article 7, and Indian taxation then depends on the existence of a permanent establishment in India. On the stated facts, the services were shown to be part of the taxpayer's business and no permanent establishment was established, so the receipts were not taxable in India under the residuary article and the addition was set aside. en-us Fri, 31 May 2024 00:00:00 +0530 Tue, 02 Jun 2026 11:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753539 Where the India-Thailand DTAA contains no separate article for fees for technical services, such receipts are not moved to the residuary article if they arise in the ordinary course of the enterprise's business. The proper treaty character is business profits under Article 7, and Indian taxation then depends on the existence of a permanent establishment in India. On the stated facts, the services were shown to be part of the taxpayer's business and no permanent establishment was established, so the receipts were not taxable in India under the residuary article and the addition was set aside. Case-Laws Income Tax Fri, 31 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753539