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Income Tax - Highlights / Catch Notes

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Income deemed to accrue or arise in India - Revenue has failed ...

Income Tax

August 29, 2023

Income deemed to accrue or arise in India - Revenue has failed to establish on record through credible evidence that the assessee has a fixed placed PE in India through which it has earned the income relating to sale of software licence. Therefore, in our considered opinion, no part of such income can be attributed to the PE - AT

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