TMI BlogIncome accrued in India - though the assessee had business connection, it did not have any fixed place...Income accrued in India - though the assessee had business connection, it did not have any fixed place PE or agency place PE in India, and, in the absence of any PE in India, the profits, if any, attributable to India’s operation could not be assessed as business profits under Article 7 of the Treaty. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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