Legal services are not fees for technical services; fiscal transparency requires partner-wise treaty analysis for non-UK partners.

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....Legal services rendered by the partnership were treated as professional services, not fees for technical services; receipts from Indian engagements could not be taxed under section 9(1)(vii), and the related addition was deleted. The Tribunal also held that a UK partnership was fiscally transparent under UK law, so treaty protection under the India-UK DTAA extends only to the extent the income is taxed in the UK as income of a resident. Non-UK resident partners could not invoke the India-UK DTAA merely by being partners in the firm; their taxability had to be examined under the DTAAs of their respective countries of residence. The matter was remanded to the Assessing Officer for that limited examination.....