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    <title>2016 (4) TMI 413 - ITAT KOLKATA</title>
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    <description>The Tribunal ruled in favor of the Assessee, a foreign company from the UK, in a tax dispute with the Revenue. It held that the Assessee did not have a Permanent Establishment (PE) in India, therefore payments received in USD were not taxable in India. However, disallowances under sections 40(a)(i) and 40(a)(ia) were upheld, along with the grossing up of the USD component of receipts. The Tribunal directed the allowance of prior period expenses in the appropriate assessment year and ruled that no interest under sections 234B and 234C was payable by the Assessee.</description>
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