https://www.taxtmi.com/caselaws?id=468132 Under the India-UK DTAA, underwriting commission and reimbursement of expenses received for issue of GDRs/FCCBs were treated as business income, not fees for technical services, because the services were not made available in the treaty sense and no attribution to a permanent establishment in India was shown. The Tribunal followed its earlier decision in the assessee's own case and Raymond Ltd, and applied section 90(2) to give effect to the more beneficial treaty treatment. The receipts were therefore not chargeable to tax in India, and the Revenue's challenge failed. en-us Thu, 13 Apr 2017 00:00:00 +0530 Fri, 17 Apr 2026 15:27:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468132 Under the India-UK DTAA, underwriting commission and reimbursement of expenses received for issue of GDRs/FCCBs were treated as business income, not fees for technical services, because the services were not made available in the treaty sense and no attribution to a permanent establishment in India was shown. The Tribunal followed its earlier decision in the assessee's own case and Raymond Ltd, and applied section 90(2) to give effect to the more beneficial treaty treatment. The receipts were therefore not chargeable to tax in India, and the Revenue's challenge failed. Case-Laws Income Tax Thu, 13 Apr 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468132