https://www.taxtmi.com/caselaws?id=793805 Receipts attributable to non-UK resident partners of a UK partnership had to be tested under the relevant DTAA of each partner's country of residence, because the firm was treated as tax transparent in the UK and partner-level treaty entitlement depended on residence. Legal services rendered by the firm were held to be professional services, not fees for technical services under section 9(1)(vii), so the addition on that basis was deleted. The treaty position of the UK, German and other non-UK partners was to be examined separately under the India-UK, India-Germany and other applicable DTAAs, and the matter was remitted for that limited purpose. en-us Mon, 22 Jun 2026 00:00:00 +0530 Wed, 24 Jun 2026 07:08:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793805 Receipts attributable to non-UK resident partners of a UK partnership had to be tested under the relevant DTAA of each partner's country of residence, because the firm was treated as tax transparent in the UK and partner-level treaty entitlement depended on residence. Legal services rendered by the firm were held to be professional services, not fees for technical services under section 9(1)(vii), so the addition on that basis was deleted. The treaty position of the UK, German and other non-UK partners was to be examined separately under the India-UK, India-Germany and other applicable DTAAs, and the matter was remitted for that limited purpose. Case-Laws Income Tax Mon, 22 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793805