https://www.taxtmi.com/caselaws?id=469079 Receipts from services rendered to Indian group companies were held not taxable under the residuary Article 22(3) of the India-Thailand DTAA because the treaty contained no separate fee for technical services clause. Where the services formed part of the enterprise's regular business activities, Article 7 applied instead, and Indian taxability depended on the existence of a permanent establishment and attribution of profits to it. On the facts, the assessee had no permanent establishment in India and the Revenue did not rebut the evidence that the services were rendered in the normal course of business, so the addition was deleted. en-us Wed, 08 Oct 2025 00:00:00 +0530 Mon, 01 Jun 2026 18:58:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469079 Receipts from services rendered to Indian group companies were held not taxable under the residuary Article 22(3) of the India-Thailand DTAA because the treaty contained no separate fee for technical services clause. Where the services formed part of the enterprise's regular business activities, Article 7 applied instead, and Indian taxability depended on the existence of a permanent establishment and attribution of profits to it. On the facts, the assessee had no permanent establishment in India and the Revenue did not rebut the evidence that the services were rendered in the normal course of business, so the addition was deleted. Case-Laws Income Tax Wed, 08 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469079