https://www.scconline.com/blog/post/2020/12/22/itat-legal-fees-paid-to-a-partnership-firm-of-lawyers-can-indeed-be-subjected-to-levy-of-tax-under-art-12-of-indo-japanese-tax-treaty-foreign-tax-credit-allowed-under-the-treaty/
ITAT | "Legal fees paid to a partnership firm of lawyers can indeed be subjected to levy of tax under Art. 12 of Indo-Japanese Tax Treaty"; Foreign Tax Credit allowed under the treaty