[ compiled answer ]
law as at 10 Jul 2026 · judicial
Can the India–UAE service PE limb be met without physical presence in India?
The compiled answer
Contested. ABB FZ (ITAT Bangalore 2017) held the India–UAE services limb can be satisfied without physical presence in India — against the territorial-nexus orthodoxy of the e-Funds line. The corridor carries both readings: a remote-delivery arrangement into India under this treaty cannot be cleared on the physical-absence ground alone.
Pinpoint
Article 5(2) services limb, India–UAE DTAA (1993); ABB FZ (ITAT Bang. 2017)
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