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    <description>Specialised equipment and personnel stationed on a contractor&#039;s vessel in India were treated as a fixed place Permanent Establishment under Article 5(1) of the India-UAE DTAA because the place was at the enterprise&#039;s disposal with sufficient permanence. On that basis, offshore supplies were held taxable in India as attributable to the Indian business connection. The Tribunal left section 44BB applicability open for limited verification, directing relief only if the contracts were found inextricably connected with prospecting or production of mineral oil. Following binding precedent, interest under section 234B was deleted for the non-resident assessee where tax was deductible at source.</description>
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