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of Income accrued in India - Permanent Establishment (PE) in India under Article–5 of the India–Mauritius Tax Treaty - The two companies were not exclusively working for the assessee and are having their independent status - Services provided to the assessee by them are in the ordinary course of their business. - They cannot be considered as dependent agent so as to constitute a PE - assessee does not have a PE in India even under Article-5(5) of the Tax Treaty - AT
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