Held that the assessee, a Limited Liability Partnership (LLP) and tax resident of UK, provided legal services to its clients worldwide, it is  entitled to benefit of article 4(1) of India-UK DTAA in respect of income generated from professional services rendered in India which had been taxed in UK in hands of its UK tax resident partners. Held that remuneration received by assessee for providing legal services was not FTS.Held that since employees of assessee for rendering services in India stayed for only 17 days and only when it amounts to 90 days or more, assessee was said to have a permanent establishment (PE) and, thus, assessee did not have a PE in India.   Held that since article 15 of India-UK DTAA deals with only for taxability of independent personnel services or independent activity and not for other persons, assessee being a partnership firm LLP, amount of fee received by assessee would not be liable to be taxed in its hands under article 15 of India-UK  (AY. 2016-17)