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2024 (2) TMI 1112 - AT - Income TaxTaxability of income in India - income accrue or arise in India or not - make available any technical knowledge, skill, know-how or process or not? - HELD THAT:- As relying on assessee own case [2022 (11) TMI 1313 - ITAT PUNE] for A.Y. 2017-18 as assessee is entitled for benefit of “India USA DTAA” and since the condition of ‘make available’ has not been satisfied in the case of the assessee, the services are not taxable in India. Accordingly, we allow the appeal of the assessee.
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