https://www.taxtmi.com/caselaws?id=773282 Design review service receipts from an Indian customer were held to fall within the business profits article of the India-UAE DTAA because the treaty contained no specific article taxing fees for technical services. Domestic characterization under section 9(1)(vii) of the Income-tax Act, 1961 could not be imported to enlarge treaty taxation where the treaty was more beneficial to the assessee. As the assessee had no permanent establishment in India, the business profits were not taxable in India, and the addition treating the amount as fees for technical services was deleted. en-us Wed, 11 Jun 2025 00:00:00 +0530 Thu, 21 May 2026 17:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773282 Design review service receipts from an Indian customer were held to fall within the business profits article of the India-UAE DTAA because the treaty contained no specific article taxing fees for technical services. Domestic characterization under section 9(1)(vii) of the Income-tax Act, 1961 could not be imported to enlarge treaty taxation where the treaty was more beneficial to the assessee. As the assessee had no permanent establishment in India, the business profits were not taxable in India, and the addition treating the amount as fees for technical services was deleted. Case-Laws Income Tax Wed, 11 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773282