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2004 (12) TMI 13 - AAR - Income TaxFor Modernisation of Air Traffic Services (MATS) in Delhi and Mumbai, the applicant entered into two contracts-(1) supply contract and (2) service contract-with USA company for supply and installation of equipment – held that the payment received by USA Company under the transaction mentioned in annexure I is not liable to tax in India in the hands of the recipient, non-resident US company - deputation of an engineer by Company to India will not constitute Company’s PE in India
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