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2004 (11) TMI 102 - AAR - Income TaxIn view of the fact that custodian cannot be treated as a permanent establishment, brokers and bankers cannot also be treated as a permanent establishment, held that income derived by the applicant, a company incorporated in and a tax resident of the UK from trading in exchange traded derivative instruments in India would not be taxable in India having regard to the provisions of the Double Taxation Avoidance Agreement between India and the UK.
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