In a decision issued in May 2015, the High Court of Uttarakhand, India held that interest on an income tax refund should be treated as business income under Article 7 (Business Profits) of the 1993 tax treaty with the UK. In addition, the Court held that such interest income could not benefit from the presumptive tax provisions of Section 44BB of the Tax Code (taxable income equal to 10% of the amount paid or payable). The case involved a UK tax resident that was engaged in providing services and facilities in connection with the exploration, extraction and production of mineral...