India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes.

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....Under the India-UK DTAA, telecommunication-service receipts are treated as business profits rather than royalty or fees for technical services where treaty characterisation remains unchanged by unilateral domestic-law amendments absent bilateral renegotiation. On that basis, the taxability challenge concerning those receipts succeeded on merits. Reopening and limitation issues remained open, while a remaining ground was not pressed.....