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2015 (1) TMI 1418 - BOMBAY HIGH COURTDTAA benefit - Proof of establishments abroad - Permanent establishments or branches outside India generated income - HELD THAT:- AO was satisfied that the benefit of the Double Taxation Avoidance Agreement is admissible provided the proof is produced in relation to payment of taxes by the Assessee abroad. If the Assessee has permanent establishment abroad, then, the Assessee would have to produce evidence regarding payment of taxes pertaining to the income of these establishments abroad. On production of such evidence, the Assessee would be entitled to the benefit. That evidence was always available and as noted by the CIT (Appeals) and the Tribunal. The authorities did nothing but follow their earlier orders based on identical facts and circumstances. The finding of fact, therefore, cannot be termed as perverse or vitiated by any error of law apparent on the face of the record.
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