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2009 (3) TMI 38 - AAR - Income TaxApplicant (Foreign Co.) had contract with Indian Company for providing engineering services but were not provided completely because of termination of agreement in mid-way - applicant submission that services provided were performed mostly outside India are in the nature of ‘royalty’ & he did not have PE in India, is acceptable – but entire receipts representing royalty income are liable to be taxed in India, both under the IT Act, 1961 as well as DTAA - splitting up of income not permissible
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