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2019 (12) TMI 769 - AT - Income TaxService PE in India - Royalty - attribution of profit - AO has erred in holding that Appellant has a service Permanent Establishment (“PE”) in India within the meaning of Article 5 of India UK Double Taxation Avoidance Agreement (“DTAA”) - Whether Appellant has a service PE in India under Article 5(2)(k) of the DTAA? - HELD THAT:- Following the decision in own case [2018 (9) TMI 961 - ITAT DELHI], decided in favor of assessee.
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