https://www.taxtmi.com/caselaws?id=468672 Under the India-UK DTAA, a service permanent establishment requires services to be furnished in India through employees or other personnel physically present in India for the prescribed period. Remote delivery by email, conference calls or virtual meetings does not create a service PE where the treaty contains no express concept of a virtual service PE. The treaty was construed strictly, and no new taxing fiction could be implied. On the stated facts, no employee or personnel of the assessee visited India, so the receipts could not be taxed in India on a service PE basis, and the alternative issue of profit attribution did not survive. en-us Fri, 20 Mar 2026 00:00:00 +0530 Fri, 15 May 2026 20:34:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468672 Under the India-UK DTAA, a service permanent establishment requires services to be furnished in India through employees or other personnel physically present in India for the prescribed period. Remote delivery by email, conference calls or virtual meetings does not create a service PE where the treaty contains no express concept of a virtual service PE. The treaty was construed strictly, and no new taxing fiction could be implied. On the stated facts, no employee or personnel of the assessee visited India, so the receipts could not be taxed in India on a service PE basis, and the alternative issue of profit attribution did not survive. Case-Laws Income Tax Fri, 20 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468672