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Business connection in India - Existence of Fixed PE In India and service PE In India - s even if assumed that there is a PE in India of the assessee no profit can be attributed to it as FAR (Functions performed Assets deployed and Risk Assumed) such PE has already been compensated at arm s length price and therefore nothing more should be attributed to it. - Tri

Income Tax - Business connection in India - Existence of Fixed PE In India and service PE In India - s even if assumed that there is a PE in India of the assessee no profit can be attributed to it as .....

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