Even prior to 2013 India-UK protocol benefit of DTAA was allowed to fiscally transparent firm establ

IT/ILT: Where non-resident partnership was a firm under section 2(23)(i) and therefore it was a 'person' under section 2(31)(iv) and attracted operation of paragraph 2 of article 3 of Indo-UK treaty, revenue's view that said partnership was not covered by said convention failed