Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent establishment.

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....Protective assessment cannot be used to tax identical receipts in the same taxpayer's hands under alternative characterisations as business income and fees for technical services; the Revenue must adopt one assessment method. The notes state that remotely rendered services, without employee visits to India, did not create a permanent establishment under the India-UK DTAA, so business-income taxation under section 44DA was deleted. For fees for technical services, the post-2020 contractual arrangements require fresh examination of whether the services made technical knowledge or capability available to the Indian recipient; specialised services alone are insufficient. The fees-for-technical-services issue was remanded for verification, including UK tax treatment.....