TMI BlogForeign exchange services under Article 13 of Indo-UK DTAA classified as royalty, PE assessment not required.Foreign exchange system services provided - Article 13 Indo-UK DTAA – once the receipt has been decided as royalty in nature then there is no need to go into the question of assessee having PE in India - - AT ..... X X X X Extracts X X X X X X X X Extracts X X X X
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