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2014 (3) TMI 1109 - ITAT PUNEPE in India - Income accrual in India - Held that:- We are not inclined to interfere with the finding of CIT(A), who has held that the assessee does not have PE in India. Under the facts and circumstances, no revenue earned by assessee could be said to be attributable to PE, even if one was to come to the conclusion that a PE, even if no taxability could arise under Article 7. The assessee has offered the royalties and fee for technical services for taxability in India under article 12A and to that extent, admitted tax liability exists. This approach of Assessing Officer was rejected by CIT(A) in A.Y. 2006-07, which was upheld by us. Following the same reasoning, we uphold the order of CIT(A) on the issue. - Decided against revenue
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