https://www.taxtmi.com/caselaws?id=784783 A non-resident's consultancy and management advisory income from an Indian payer was examined under the domestic deeming rule of significant economic presence in section 9(1)(i), but the Tribunal held that the applicable India-UAE DTAA governed the tax treatment. The services were treated as falling within Article 14's inclusive definition of professional services, and section 90(2) entitled the assessee to the more beneficial treaty position. In the absence of a fixed base in India or other treaty conditions for source taxation, the income could not be taxed in India, and the addition was held unsustainable. en-us Fri, 05 Dec 2025 00:00:00 +0530 Mon, 12 Jan 2026 09:31:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784783 A non-resident's consultancy and management advisory income from an Indian payer was examined under the domestic deeming rule of significant economic presence in section 9(1)(i), but the Tribunal held that the applicable India-UAE DTAA governed the tax treatment. The services were treated as falling within Article 14's inclusive definition of professional services, and section 90(2) entitled the assessee to the more beneficial treaty position. In the absence of a fixed base in India or other treaty conditions for source taxation, the income could not be taxed in India, and the addition was held unsustainable. Case-Laws Income Tax Fri, 05 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784783