Certainly a ‘Person’ in its own right! German Partnership firm eligible for Treaty Benefits

The Mumbai Bench of the Income Tax Appellate Tribunal (“ITAT”) held that a Limited Partnership Firm with the suffix “GmbH and Co. Kg”, incorporated under the law of Germany, is a “person” as defined in the India-Germany Double Taxation Avoidance Agreement (DTAA) because it is assessed for “Trade Tax” in Germany and would be entitled to benefits under the India-Germany Tax Treaty.