Sec. 9 of the Income-tax Act, 1961 - Income - Revenue filed appeal against the order of Tribunal in holding that the amount received as reimbursement of lease line charges is not liable to be taxed as business profit under article 7 read with article 5 of India UK DTAA (Income Tax Appeal No. 890/15) and India US DTAA (Income Tax Appeal No. 891/15) in view of the Force of Attraction Rule. Since, similar questions raised for assessment year 2004-05 in DIT IT (International Taxation) v. WNC Global Services, (UK) Ltd. [2013] 32 taxmann.com 54/214 Taxman 317 (Bom.) was not entertained, as it was a finding of fact, the appeal of the revenue dismissed. SLP of the revenue also dismissed on due to low tax effect. - CIT V/s WNS NORTH AMERICA INC. - [2020] 272 TAXMAN 431 (SC)