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. The notes state that an earlier consolidated hearing mainly concerned group entities covered by another treaty and did not allow the assessee to address its treaty-specific facts. They identify recall of the earlier order and a fresh hearing on all relevant issues, including the existence or absence of a permanent establishment, as warranted. 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. The notes state that an earlier consolidated hearing mainly concerned group entities covered by another treaty and did not allow the assessee to address its treaty-specific facts. They identify recall of the earlier order and a fresh hearing on all relevant issues, including the existence or absence of a permanent establishment, as warranted. Case-Laws Income Tax Mon, 29 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470566