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2022 (2) TMI 697 - AT - Income TaxIncome accrued in India - income of the assessee from contracts entered into on or after 1st April, 2003 - whether effectively connected to PE of the assessee and 'not FTS' and liable to tax on net basis as per provisions of section 44DA? - HELD THAT:- As decided in own case [2018 (6) TMI 401 - ITAT DELHI] assessee's receipts from the contracts in India are not effectively connected with PE in India. Accordingly,as directed the Assessing Officer to tax such receipts on net basis as per section 44DA of the Act. - Decided against Revenue.
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