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2015 (12) TMI 904 - AT - Income TaxIncome earned from customers outside India - whether is liable to tax in India under DTAA with USA? - assessee’s claim that the software provided to the representatives did not constitute PE - Held that:- There is no agency PE of the assessee in India. As in the absence of any PE in India the profits if any attributable to the Indian operations cannot be assessed as business profits under Article 7 of the Treaty. - Decided in favour of assessee.
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