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    <title>2022 (11) TMI 405 - ITAT HYDERABAD</title>
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    <description>The appeal by the Revenue was dismissed by the Tribunal. It was held that the referral fees paid to Singapore companies were not taxable in India, and no Tax Deducted at Source (TDS) was required. The Tribunal upheld the decision of the Commissioner of Income Tax (Appeals) and concluded that the referral services did not accrue or arise in India, therefore not attracting TDS provisions. The Tribunal found no concrete evidence to support the claim that the Singapore companies had a Permanent Establishment in India, ruling that mere office addresses and PAN numbers were insufficient to establish a PE.</description>
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      <description>The appeal by the Revenue was dismissed by the Tribunal. It was held that the referral fees paid to Singapore companies were not taxable in India, and no Tax Deducted at Source (TDS) was required. The Tribunal upheld the decision of the Commissioner of Income Tax (Appeals) and concluded that the referral services did not accrue or arise in India, therefore not attracting TDS provisions. The Tribunal found no concrete evidence to support the claim that the Singapore companies had a Permanent Establishment in India, ruling that mere office addresses and PAN numbers were insufficient to establish a PE.</description>
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