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 i

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