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2024 (1) TMI 788 - ITAT DELHIPE in India - accrual of income in India - offshore supply of sub-assemblies - HELD THAT:- in the assessee’s own case in [2023 (8) TMI 957 - ITAT DELHI] AY 2010-11 wherein ITAT had held that Bombardier Transportation India Pvt. Ltd. (BTIL) is not PE of the assessee in India and accordingly, since there is no PE of the assessee in India, the offshore supply of sub-assemblies to BTIL/income from intermediary services cannot be taxed in India. Decided in favour of assessee.
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