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    <description>The court ruled that the payments received for lighting and searchlight services were taxable in India as Business Profits under the India-Belgium DTAA and the Income Tax Act, 1961. The court found that the Applicant had a Permanent Establishment in India and that the payments did not constitute royalty or Fees for Technical Services. Therefore, the income was classified as Business Profits and subject to taxation in India.</description>
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      <description>The court ruled that the payments received for lighting and searchlight services were taxable in India as Business Profits under the India-Belgium DTAA and the Income Tax Act, 1961. The court found that the Applicant had a Permanent Establishment in India and that the payments did not constitute royalty or Fees for Technical Services. Therefore, the income was classified as Business Profits and subject to taxation in India.</description>
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