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2008 (8) TMI 893 - SCH - Income TaxExtract: .......he DTAA. However, we find that this finding has been given on the basis that there is no evidence or justification forthcoming from the side of the Department to show that the respondent is a PE. On that account alone, we do not wish to interfere in this matter. For the afore-stated reasons, this Civil Appeal stands dismissed. No order as to costs.
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