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    <title>2016 (6) TMI 1441 - ITAT DELHI</title>
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    <description>A project office acting only as a communication channel was treated as preparatory or auxiliary activity and did not constitute a permanent establishment in India under the India-UAE DTAA. On those facts, no income from offshore supplies or onshore contract activities could be attributed to India, and the related additions could not be sustained. The Tribunal also noted that interest under section 234B was not leviable in the non-resident tax withholding context and directed credit for tax deducted at source to be allowed in accordance with law. The document emphasises that, absent a PE, contract receipts are not taxable in India and attribution to a PE does not arise.</description>
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