The CBDT has issued Circular No. 02/2016 dated 25.02.2016 in which it has clarified that the provisions of the India-UK DTAA would be applicable to a partnership. that is a resident of either India or UK, to the extent that the income derived by such partnership, estate or trust is subject to tax in that State as the income of a resident, either in its own hands or in the hands of its partners or beneficiaries
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