https://www.taxtmi.com/caselaws?id=774369 Service receipts from an Indian payer were disputed as either taxable as "Other Income" under Article 22 of the India-Thailand DTAA or examinable under the business profits article in the absence of a permanent establishment in India. The Tribunal noted that the characterisation depended on the underlying services and contractual material, but the DRP had treated relevant service agreements and annexures as missing from the record. As no challenge was pressed to that factual finding and no additional evidence application was before the Tribunal, the matter was remitted to the DRP for fresh consideration on a fuller record. The substantive taxability issue was therefore left open. en-us Fri, 04 Jul 2025 00:00:00 +0530 Tue, 08 Jul 2025 08:36:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774369 Service receipts from an Indian payer were disputed as either taxable as "Other Income" under Article 22 of the India-Thailand DTAA or examinable under the business profits article in the absence of a permanent establishment in India. The Tribunal noted that the characterisation depended on the underlying services and contractual material, but the DRP had treated relevant service agreements and annexures as missing from the record. As no challenge was pressed to that factual finding and no additional evidence application was before the Tribunal, the matter was remitted to the DRP for fresh consideration on a fuller record. The substantive taxability issue was therefore left open. Case-Laws Income Tax Fri, 04 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774369