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1998 (7) TMI 693 - ADVANCE RULING AUTHORITYWhether the provisions of section 115JA of the Act would be applicable in computing the total income of a foreign company like the applicant ? Whether in computing the profit attributable to the permanent establishment (‘‘PE’’) of the applicant which is a tax resident of Netherlands, recourse can be had to provisions of section 115JA, having regard to the provisions of the convention for avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and on capital entered into by India with the Netherlands (‘‘the treaty’’) ?
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