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    <title>2016 (2) TMI 47 - DELHI HIGH COURT</title>
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    <description>The court held that the Assessee did not have a Permanent Establishment (PE) in India as defined in the Double Taxation Avoidance Agreement (DTAA) with the UAE. The Project Office in Mumbai was deemed to have activities of a preparatory or auxiliary character, excluding it from constituting a PE. Additionally, the court found that the Assessee did not have an Installation PE or a Dependent Agent PE in India. Consequently, no income could be attributed to the Assessee&#039;s PE, leading to the setting aside of assessment and ITAT orders for the relevant years. The appeals were disposed of with parties bearing their own costs.</description>
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      <title>2016 (2) TMI 47 - DELHI HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=271342</link>
      <description>The court held that the Assessee did not have a Permanent Establishment (PE) in India as defined in the Double Taxation Avoidance Agreement (DTAA) with the UAE. The Project Office in Mumbai was deemed to have activities of a preparatory or auxiliary character, excluding it from constituting a PE. Additionally, the court found that the Assessee did not have an Installation PE or a Dependent Agent PE in India. Consequently, no income could be attributed to the Assessee&#039;s PE, leading to the setting aside of assessment and ITAT orders for the relevant years. The appeals were disposed of with parties bearing their own costs.</description>
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