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    <description>Crane-renting operations in India were treated as giving rise to a permanent establishment, and the attributable business profits were held taxable in India. The ruling proceeded on the applicant&#039;s acceptance of the Revenue&#039;s treaty and charging provisions, so the Indian operations were treated as income arising in India. For computation, the business profits attributable to the permanent establishment were to be assessed under the applicable statutory and treaty framework, including Section 44BB. The reference was disposed of on that agreed basis.</description>
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      <description>Crane-renting operations in India were treated as giving rise to a permanent establishment, and the attributable business profits were held taxable in India. The ruling proceeded on the applicant&#039;s acceptance of the Revenue&#039;s treaty and charging provisions, so the Indian operations were treated as income arising in India. For computation, the business profits attributable to the permanent establishment were to be assessed under the applicable statutory and treaty framework, including Section 44BB. The reference was disposed of on that agreed basis.</description>
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