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2018 (11) TMI 783 - AT - Income TaxAddition for payment of supply of software - nature of Royalty as per Article 12 of the India-Israel DTAA - taxability in India - PE in India - Held that:- Referring to assessee’s own case, we hold that TTI India cannot be treated as assessee’s dependent agent PE in India, hence, the amount is not taxable at the hands of the assessee. The grounds are allowed.
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