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2007 (9) TMI 462 - AT - Income TaxExtract: .......t since, German company is not having PE in India, the impugned payment is not taxable in the hands of the German company as business income or as capital gains. In view of the above discussion, we find no reason to interfere in the order of learned CIT(A) and hence, we uphold the same. 9. In the result, this appeal of the revenue stands dismissed.
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