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2006 (2) TMI 77 - AAR - Income TaxNon-resident company - leading investment Bank having a number of group companies in various parts of the world - provides financial advisory services, corporate lending and securities underwriting by various divisions – One of the group companies is a Morgan Stanley Advantage Services Private Limited ("MSAS") which is incorporated in India and is set up by the Morgan Stanley Group – held that MSAS is not the PE of the applicant in India & MSAS would not constitute an agency PE of the applicant
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