https://www.taxtmi.com/caselaws?id=796666 Offshore conversion and construction services performed wholly in the UAE are treated as business income under the India-UAE DTAA, which contains no separate fees-for-technical-services article. In the absence of an Indian permanent establishment, the receipts are not taxable in India. A final assessment completed before the Dispute Resolution Panel issued directions is legally invalid where it was finalised on the assumption that no objections had been filed. The premature assessment was therefore quashed. en-us Wed, 14 Jan 2026 00:00:00 +0530 Sat, 08 Aug 2026 08:32:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796666 Offshore conversion and construction services performed wholly in the UAE are treated as business income under the India-UAE DTAA, which contains no separate fees-for-technical-services article. In the absence of an Indian permanent establishment, the receipts are not taxable in India. A final assessment completed before the Dispute Resolution Panel issued directions is legally invalid where it was finalised on the assumption that no objections had been filed. The premature assessment was therefore quashed. Case-Laws Income Tax Wed, 14 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796666