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2004 (5) TMI 60 - AUTHORITY FOR ADVANCE RULINGSApplicant, a limited liability company incorporated in UAE, is engaged in offering, among others, remittance services for transferring amounts from UAE to various places in India - it was granted licence by RBI for the purpose of setting up liaison offices in India - that so much of the profits as shall be deemed to accrue or arise to the applicant in India which are attributable to the "PE", namely, the liaison offices in India, would be taxable in India even under the DTAA.
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