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1991 (7) TMI 126 - AT - Income TaxExtract: ....... the result, for the discussion aforesaid, we are of the opinion that the fees received by the assessee was in the nature of industrial and commercial profit and assessee having no permanent establishment in India, the fees received would not be taxable in India by virtue of article III of AADT with Denmark. 11. In the result, the appeal is allowed
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