https://www.taxtmi.com/caselaws?id=469059 Receipts from technical services rendered to Indian group entities were treated as business profits under Article 7 of the India-Thailand DTAA, because the treaty contained no specific article for fees for technical services and such income could not be forced into the residuary article merely for being technical in character. Taxation in India required a permanent establishment and attribution to that establishment; in the absence of a permanent establishment, the income was not taxable in India under Article 22 or section 9(1)(vii), and the addition could not be sustained. en-us Thu, 27 Jun 2024 00:00:00 +0530 Mon, 01 Jun 2026 18:58:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469059 Receipts from technical services rendered to Indian group entities were treated as business profits under Article 7 of the India-Thailand DTAA, because the treaty contained no specific article for fees for technical services and such income could not be forced into the residuary article merely for being technical in character. Taxation in India required a permanent establishment and attribution to that establishment; in the absence of a permanent establishment, the income was not taxable in India under Article 22 or section 9(1)(vii), and the addition could not be sustained. Case-Laws Income Tax Thu, 27 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469059