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of Income taxable in India or not - FTS/FIS - payments received by the assessee from its Indian customers on account of Centralized Services - absence of PE in India - The Tribunal upheld CIT(A)'s decision, emphasizing the payments received for Centralized Services are not to be classified as FTS/FIS under the Act or India-USA DTAA, aligning with precedent judgments. It was highlighted that such income constitutes business profits, not taxable in India in the absence of a Permanent Establishment (PE) of the assessee, as per the DTAA.
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