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SECTION 9 OF THE INCOME-TAX ACT, 1961 – INCOME – DEEMED TO ACCRUE OR ARISE IN INDIA

April 27, 2024

Resident – Company, liable to tax, connotation of : Where assessee, a Limited Liability Partnership (LLP) and tax resident of UK, provided legal services to its clients worldwide, it was entitled to benefit of article 4(1) of India-UK DTAA on portion of its income from Indian engagements, which had been taxed in UK in hands of its UK tax resident partners – Herbert Smith Free LLP v. Deputy Commissioner of Income-tax – [2024] 161 taxmann.com 708 (Delhi – Trib.)

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