On 13 May 2013, the Special Bench of the Income Tax Appellate Tribunal issued its judgment in the case of ADIT vs. Clifford Chance. The Tribunal ruled that professional services fees would be taxable to the extent of the services actually rendered in India. The term “directly or indirectly attributable to a permanent establishment” does not pre-suppose a force of attraction rule under article 7 (1) of the India and UK Income Tax Treaty in 1993.