https://www.taxtmi.com/caselaws?id=470566 Taxability of business profits under the India-UK treaty depended on whether the assessee had a permanent establishment in India during the relevant year. Although the receipt was characterised as business profits rather than fees for technical services, the relevant facts had not been specifically addressed because the consolidated hearing primarily concerned group entities governed by a different treaty. A fresh opportunity was warranted to address the applicable treaty provisions and all relevant permanent-establishment issues, requiring recall of the earlier order for rehearing. en-us Mon, 29 Dec 2025 00:00:00 +0530 Fri, 31 Jul 2026 08:27:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470566 Taxability of business profits under the India-UK treaty depended on whether the assessee had a permanent establishment in India during the relevant year. Although the receipt was characterised as business profits rather than fees for technical services, the relevant facts had not been specifically addressed because the consolidated hearing primarily concerned group entities governed by a different treaty. A fresh opportunity was warranted to address the applicable treaty provisions and all relevant permanent-establishment issues, requiring recall of the earlier order for rehearing. Case-Laws Income Tax Mon, 29 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470566