Linklaters Llp vs Income Tax Officer (International Taxation)*
Whether a UK-based law firm's activities in India constitute a Permanent Establishment (PE) under Article 5(2)(k) of India-UK DTAA --- Held Yes. Whether income attributable to the PE should be computed based on actual billing rates or hypothetical market rates --- Held Actual billing rates. Whether services rendered outside India for Indian projects are taxable in India --- Held No, only services rendered in India are taxable.
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