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2004 (9) TMI 100 - AAR - Income TaxApplicant, a non-resident, is a trust, set up to provide investors a continuous source of managed investments in securities - applicant has no PE in India in terms of article 5 of the treaty, therefore, the gains arising from the sales of portfolio investments in India are the applicant's business profits, covered under article 7 of the Convention dated December 20, 1990, regarding the Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion (Treaty)
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