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1996 (2) TMI 560 - AAR - Income TaxExtract: ....... articles 5.5 and 5.6 of the DTA considered along with the four proposed agreements between the applicant and the subsidiary referred to above. Question B The extent of the income deemed to accrue or arise in India will depend on the actual working of the applicant and the subsidiary. Thus, this question cannot be answered in a hypothetical manner.
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