https://www.taxtmi.com/highlights?id=71722 Income deemed to accrue or arise in India - Revenue has failed to establish on record through credible evidence that the assessee has a fixed placed PE in India through which it has earned the income relating to sale of software licence. Therefore, in our considered opinion, no part of such income can be attributed to the PE - AT en-us Tue, 29 Aug 2023 08:37:52 +0530 Tue, 29 Aug 2023 08:37:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=71722 Income deemed to accrue or arise in India - Revenue has failed to establish on record through credible evidence that the assessee has a fixed placed PE in India through which it has earned the income relating to sale of software licence. Therefore, in our considered opinion, no part of such income can be attributed to the PE - AT Highlights Income Tax Tue, 29 Aug 2023 08:37:52 +0530 https://www.taxtmi.com/highlights?id=71722