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    <title>2016 (2) TMI 923 - ITAT MUMBAI</title>
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    <description>Identical taxability issues already settled in the assessee&#039;s own earlier years were followed for the later years, so advertisement revenue was treated as not taxable in India for want of a business connection or permanent establishment. Distribution receipts were also held not taxable as royalty or business income, and the presence of arm&#039;s length remuneration to the Indian group entity did not alter that position. Interest on tax refunds was dealt with under the earlier treaty-based ruling and the special bench view, leaving no separate adverse tax consequence on the alternative grounds.</description>
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