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2009 (4) TMI 16 - AAR - Income TaxProfessional services to the energy and resource industries including engineering, procurement and project management services - six separate contracts with ONGC - After hearing the matter, AAR has decided that in certain cases there is no royalty which is taxable in India and No PE in India and in certain other cases, appellant is liable to pay Income Tax on Royalties in India and Royalties are taxable irrespective there is PE in India or not.
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