Fiscally transparent partnership firm eligible for tax treaty benefits and application of “force of attraction” rule to profits indirectly attributable to PE

Facts The assessee is a UK based partnership firm engaged in the practice of law. The assessee did not have any branch office or other similar form of presence in India. During the financial year 1995- 96, the assessee rendered services (partly from London and partly from India) to certain clients in connection with projects in India. The assessee?s partners / staff were present in India for a period exceeding 90 days. The assessee filed a nil return of income claiming that it did not have a permanent establishment (PE) or fixed base in India and therefore, its income from services rendered i...