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2023 (11) TMI 644 - AT - Income TaxIncome accrued in India - PE in India - HELD THAT:- As none of the conditions of fixed place PE as enshrined under Article 5(1) of India – Germany tax treaty stand satisfied Project Office at Vadodara does not constitute Fixed Place Permanent Establishment of the assessee company and BTIL does not constitute fixed place PE of the assessee company, is upheld and issue decided in favour of the assessee.
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