Tax benefit of India-UK DTAA available to LLP on Indian engagement income

Herbert Smith Freehills LLP Vs ACIT (ITAT Delhi) ITAT Delhi held that benefit of India-UK DTAA is available to Limited Liability Partnership on the portion of income from Indian engagement. Facts- The assessee is a firm of solicitors, having its registered office in the United Kingdom and is engaged in providing legal services to its clients worldwide (non-residents and residents of India). The assessee is a UK based Limited Liability Partnership with a majority of its partners being tax residents of the UK. During the previous year under consideration, the assessee provided legal services to ...