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    <title>2010 (5) TMI 674 - ITAT MUMBAI</title>
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    <description>The Tribunal upheld the CIT (Appeals)&#039;s findings that the lease was a bareboat lease. The income received as royalty was not taxable under the DTAA. The assessee did not have a PE in India. The levy of interest under section 234B was consequential and thus dismissed. The appeals by the revenue were dismissed, and the cross-objection by the assessee was also dismissed.</description>
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      <description>The Tribunal upheld the CIT (Appeals)&#039;s findings that the lease was a bareboat lease. The income received as royalty was not taxable under the DTAA. The assessee did not have a PE in India. The levy of interest under section 234B was consequential and thus dismissed. The appeals by the revenue were dismissed, and the cross-objection by the assessee was also dismissed.</description>
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